Greenhouse Gas Emissions Standards for Heavy-Duty Vehicles: Phase 3: Draft Regulatory Impact Analysis


&EPA

Greenhouse Gas Emissions Standards
for Heavy-Duty Vehicles: Phase 3

Draft Regulatory Impact Analysis

United States
Environmental Protection
Agency

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Greenhouse Gas Emissions Standards
for Heavy-Duty Vehicles: Phase 3

Draft Regulatory Impact Analysis

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.

Assessment and Standards Division
Office of Transportation and Air Quality
U.S. Environmental Protection Agency

NOTICE

4>EPA

United States
Environmental Protection
Agency

EPA-420-D-23-004
April 2023

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Contents

Contents	ii

List of Tables	iv

List of Figures	x

Executive Summary	xii

Chapter 1 Industry Characterization and Technologies to Reduce GHG Emissions	1

1.1	Introduction	1

1.2	Heavy-duty Vehicle Industry	1

1.3	Current Regulations and Federal Support for Reducing Heavy-Duty Vehicle GHG Emissions	13

1.4	GHG-Reducing Technologies for ICE-Powered Vehicles	23

1.5	Battery Electric Vehicle Technologies	27

1.6	BEV Charging Infrastructure	60

1.7	Fuel Cell Electric Vehicle Technology	71

1.8	Overview of Hydrogen Industry and Infrastructure	78

Chapter 1 References	87

Chapter 2 Technology Assessment 	108

2.1	Introduction	108

2.2	HD Vehicle Benchmark Characteristics	115

2.3	ICE Vehicle Technology	140

2.4	Battery Electric Vehicle Technology	157

2.5	Fuel Cell Electric Vehicle Technology	185

2.6	BEV Charging Infrastructure 	195

2.7	HD TRUCS Functionality	204

2.8	HD TRUCS Analysis Results 	233

2.9	Development of the Proposed CO2 Standards and Potential Alternative	244

Chapter 2 References	261

Chapter 3 Program Costs	272

3.1	IRA Tax Credits	274

3.2	Technology Package Costs	275

3.3	Manufacturer Costs	281

3.4	Purchaser Costs	284

3.5	Social Costs	302

Chapter 3 References	309

Chapter 4 Emission Inventories	310

4.1	Introduction	310

4.2	Model Data and Updates	310

4.3	Model Inputs and Methodology	316

4.4	National Downstream Emission Inventory Impacts of the Proposal	327

4.5	National Upstream Emission Inventory Impacts of the Proposal	344

4.6	Net Emissions Impacts of the Proposal	349

4.7	Comparison Between the Proposal and the Alternative	356

Appendix A to Chapter 4 - Updates to MOVES3.R3 for light-duty vehicles	361

Chapter 4 References	363

Chapter 5 Health and Environmental Impacts	366

5.1	Climate Change Impacts	366

5.2	Health Effects Associated with Exposure to Non-GHG Pollutants	368

5.3	Welfare Effects Associated with Exposure to Non-GHG Pollutants	388

5.4	Environmental Justice	391

Chapter 5 References	398

Chapter 6 Economic and Other Impacts	411

6.1 Impact on Sales, Fleet Turnover, Mode Shift, Class Shift, and Domestic Production	411

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6.2	Purchaser Acceptance	417

6.3	VMT Rebound	421

6.4	Employment Impacts	422

6.5	Oil Imports and Electricity Consumption	429

Chapter 6 References	432

Chapter 7 Benefits	434

7.1	Climate Benefits	434

7.2	Estimated Human Health Benefits of Non-GHG Emission Reductions	450

7.3	Energy Security	468

Chapter 7 References	486

Chapter 8 Net Benefits	492

8.1	Methods	492

8.2	Results	492

Chapter 8 References	496

Chapter 9 Small Business Analysis	497

9.1	Definition of Small Businesses	497

9.2	Categories of Small Businesses Potentially Affected by This Proposal	497

9.3	Description of Small Businesses Potentially Affected by This Proposal	498

9.4	Potential Impacts on Small Entities	500

Chapter 9 References	500

iii

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List of Tables

Table 1-1 Number ofU.S. Vehicles, Vessels, and Other Conveyances: 1990-2019	2

Table 1-2 Domestic Mode of Exports and Imports by Tonnage and Value from 2012-2045 	3

Table 1-3 Benchmarked Conventional Vehicles with Similar ZEV Options	6

Table 1-4: AEO 2022 Sales Projections in Thousands by Weight Class and Energy Use from 2022 - 2050	13

Table 1-5 Existing Phase 2 CO2 Standards for Model Year (MY) 2027 and Later Vocational Vehicles (g/ton-mile) 13
Table 1-6: Existing Phase 2 Custom Chassis CO2 Emission Standards for Model Year (MY) 2027 and Later (g/ton-

mile)58 	13

Table 1 -7: Existing Phase 2 CO2 Standards for Model Year (MY) 2027 and Later Class 7 and Class 8 Tractors (g/ton-

mile)	II

Table 1-8 Vehicle Manufacturers Certified to EPA HDV Emission Standards in MY 2022	14

Table 1-9 MY 2027 Engine CO2 Emission Standards for Engines Installed in Tractors (SET cycle)	15

Table 1-10 MY 2027 Engine CO2 Emission Standards for Heavy-Duty Engines Installed in Vocational Vehicles (FTP

cycle)	15

Table 1-11 Engine Manufacturers Certified to EPA HDE Emission Standards in MY 2022	15

Table 1-12 California Air Resource Board ACT Regulation ZEV Sales Percentage Schedule	22

Table 1-13 CARB Weight Class Modifiers	23

Table 1-11 Hybrid Heavy-Duty Vehicle Examples	23

Table 1-15 Battery weight and volume to meet vehicle requirement for two different chemistries	29

Table 1-16 Current Electronic Power Take Off Market Offerings	44

Table 1-17 Models of Battery Electric Heavy-Duty Vehicles through 2024	44

Table 1-18 List of HD BEV Purchase Commitments Compiled by EDF (2022)	51

Table 1-19 Manufacturers of HD BEV Components	59

Table 1-20 DOE Funded BEV Projects Awarded in 2022	60

Table 1-21 U.S. Charging Station Count	63

Table 1-22 U.S. EVSE Port Count	63

Table 1-24 Current and Projected North American HD Fuel Cell Vehicles	76

Table 1-25 FCEV Component Manufacturers	78

Table 1-26 DOE Funded Hydrogen HDV Projects Awarded in 2022	78

Table 1-27 Excerpt from Table 6-1 in DRIA Chapter 6.5 on Estimated U.S. Oil Import Reductions and Electricity

Consumption Increases due to the Proposal *	83

Table 2-1 HD TRUCS Vehicle Types	111

Table 2-2 50th and 90th Percentile VMT in HD TRUCS	117

Table 2-3 Energy Requirements of HDVs	121

Table 2-4 Model Year 2027 GEM Engine Parameters	124

Table 2-5 Model Year 2027 GEM Drivetrain Parameters	124

Table 2-6 Model Year 2027 GEM Tire Parameters	125

Table 2-7 Model Year 2027 GEM Other Parameters	126

Table 2-8 GEM Tractor Inputs	127

Table 2-9 GEM Vocational Vehicle Inputs	127

Table 2-10 Model Year 2027 GEM Axle Work and CO2 Emissions (HVAC load has been removed)	128

Table 2-11 GEM Duty Cycle Distance and Time	129

Table 2-12 GEM Test Cycle Weighting Factors and Average Speed	129

Table 2-13 GEM Weighted Energy Consumption per Mile	129

Table 2-14 Percent Energy Recovered from Regenerative Braking	130

Table 2-15 Energy Recovered per Mile from Regenerative Braking	131

Table 2-16 PTO Energy Use as a Function of Total Energy Consumed	132

Table 2-17 PTO Assignment in HD TRUCS	133

Table 2-18 MY 2019 CD PV Data by MOVES ID	135

Table 2-19 MOVES IDs Missing from PV Data	135

Table 2-20 Redistribution of 2019 CD PV Data to MOVES New Vehicle Sales	136

Table 2-21 MY 2019 MOVES New Vehicle Sales	137

Table 2-22 HD TRUCS Vehicle Sales	138

Table 2-23 Benchmark ICE Vehicle Dimensions and Weight	141

Table 2-24 Engine Power used as GEM Inputs and to Determine Engine Cost	144

iv

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Table 2-25 Binned Direct Manufacturing Costs for ICE Powertrain Components for MY 2032 (2021$)	146

Table 2-26 ICE Powertrain (PT) Direct Manufacturing Cost (DMC) for MY 2032 (2021$)	146

Table 2-27 GEM Fuel Consumption in Miles per Gallon Diesel (MPGD)	148

Table 2-28 Annual Diesel Fuel Consumption from Driving and PTO Use (MY 2027-2032)	149

Table 2-29 Average Annual M&R and Diesel Fuel Cost for ICE Vehicles for MY 2032 (2021$)	152

Table 2-30 DEF Consumption Rates for Diesel Vehicles in HD TRUCS	154

Table 2-31 Annual DEF Consumption	154

Table 2-32 AEO 2022 Reference Case Diesel Price (2021$)	157

Table 2-33 Battery and Motor Sizes (MY 2032)	158

Table 2-34 HD TRUCS HVAC Power Consumption of a Class 8 Transit Bus	162

Table 2-35 Distribution of VMT for HD TRUCS Temperature Bins	163

Table 2-36 HD TRUCS Surface Area as a Function of a Class 8 Truck Surface Area	163

Table 2-37 VMT Weighted Battery Conditioning Energy Consumption	165

Table 2-38 BEV Component Efficiencies in MY 2027-2032	165

Table 2-39 AXI. Performance Targets	166

Table 2-40 Battery Size, Weight, Volume, and Width in MY 2032	167

Table 2-41 Batten Pack-Level Specific Energy m HD TRUCS (Wh/kg)	169

Table 2-42 Battery Pack Level Energy Density in HD TRUCS (Wh/L)	170

Table 2-43 Pack-Level Battery Direct Manufacturing Costs in HD TRUCS (2021$)	172

Table 2-44 Pack-Level Battery Direct Manufacturing Costs and IRA Tax Credits in HD TRUCS (2021$)	173

Table 2-45 E-Motor Direct Manufacturing Costs in HD TRUCS (2021$)	175

Table 2-46 Onboard Charger Direct Manufacturing Costs in HD TRUCS (2021$)	177

Table 2-47 Direct Manufacturing BEV Costs Including IRA Tax Credit for MY 2027 (2021$)	177

Table 2-48 Direct Manufacturing BEV Costs and IRA Tax Credit for MY 2032 (2021$)	179

Table 2-49 BEV Operating Costs for a MY 2032 Vehicle (2021$)	182

Table 2-50 Price of Electricity (2021$)	185

Table 2-51 Technical Properties of the FCEV for MY 2032	186

Table 2-52 FCEV Fuel Cell Efficiencies for MY 2027-2032	188

Table 2-53 Direct Manufacturing FCEV Costs and IRA Tax Credit for MY 2032 ($2021)	189

Table 2-54 HD Fuel Cell Stack Direct Manufacturing Costs (2021$)	190

Table 2-55 Hydrogen Fuel Tank Direct Manufacturing Costs (2021$)	191

Table 2-56 FCEV Operating Costs for a MY 2032 Vehicle (2021$)	191

Table 2-57 Price of Hydrogen for CY 2027-2032 (2021$)	194

Table 2-58 Combined Hardware and Installation Costs, per EVSE Port (in 2021$)	197

Table 2-59 Average Proxy Dwell Times for Seven MOVES Vehicle Categories	199

Table 2-60 Combined Hardware and Installation EVSE Costs, per vehicle (in 2021$)	202

Table 2-61 Summary of per vehicle EVSE costs for MY 2027 and 2032 (in 2021$)	202

Table 2-62 Input Parameters for Hybrid Vehicle Model	207

Table 2-63 VMT Coefficients A and B	211

Table 2-64 Energy Consumption as a Function of Temperature Bands	214

Table 2-65 HD Vehicle Dimensions	214

Table 2-66 Pack Level Battery Properties	217

Table 2-67 Energy Consumption as a Function of Temperature Bands	222

Table 2-68 Charging Efficiency	227

Table 2-69 Example Charging Times (for 400 kWh of electricity demand)	228

Table 2-70 Example per-vehicle EVSE Costs in 2021$	228

Table 2-71 M&R Coefficients a-d	230

Table 2-72 [Removed]	231

Table 2-73 Adoption Rate Schedule in HD TRUCS	232

Table 2-74 Vehicles that Do Not Meet HD TRUCS BEV Payload Impact Criteria for MYs 2027-2032	235

Table 2-75 Results of the BEV Payback Analysis for MY 2027 (2021$)	236

Table 2-76 Results of the BEV Payback Analysis for MY 2032 (2021$)	238

Table 2-77 Results of the FCEV Payback Analysis for MY 2032 (2021$)	240

Table 2-78 HD TRUCS ZEV Adoption Rates by HD TRUCS Vehicle Type for the Proposal	240

Table 2-79 Sales-Weighted Battery Pack Size and MOVES MY2027 and MY2032 Vehicle Sales	243

Table 2-80 Projected ZEV Adoption Rates for MYs 2027 and 2032 Technology Packages	245

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Table 2-81 High-Level ZEV Adoption Rates in the Proposal	245

Table 2-82 Projected ZEV Adoption Rates for MYs 2027-2032 Technology Packages for the Proposal	247

Table 2-83 Existing MY 2027 Tractor C( >.- Emission Standards (g/ton-mile)	248

Table 2-84 Existing MY 2027 Vocational Vehicle CO2 Emission Standards (g/ton-mile)	249

Table 2-85 Example CO2 Emission Credit Calculations for Light Heavy-Duty (LHD) BEV/FCEVs by Regulatory

Subcategory based off the Existing MY 2027 standards	249

Table 2-86 Calculations of the Proposed MY 2027 CO2 Emission Standards for Vocational Vehicles	251

Table 2-87 Calculations of the Proposed MY 2028 CO2 Emission Standards for Vocational Vehicles	252

Table 2-88 Calculations of the Proposed MY 2029 CO2 Emission Standards for Vocational Vehicles	252

Table 2-89 Calculations of the Proposed MY 2030 CO2 Emission Standards for Vocational Vehicles	253

Table 2-90 Calculations of the Proposed MY 2031 CO2 Emission Standards for Vocational Vehicles	253

Table 2-91 Calculations of the Proposed MY 2032 and Later CO2 Emission Standards for Vocational Vehicles ...254

Table 2-92 Proposed MY 2027 through 2032+ Vocational Vehicle CO2 Emission Standards (g/ton-mile)	255

Table 2-93 Proposed MY 2027 through 2032+ Optional Custom Chassis Vocational Vehicle CO2 Emission Standards

(g/ton-mile)	256

Table 2-94 Proposed MY 2027 through MY 2032+ Tractor CO2 Emission Standards (g/ton-mile)	256

Table 2-95 Proposed MY 2027 through MY 2032+ Heavy-Haul Tractor CO2 Emission Standards (g/ton-mile) ....257
Table 2-96 Manufacturer Costs to Meet the Proposed MY 2027 Standards Relative to the Reference Case (2021$)

	258

Table 2-97 Manufacturer Costs to Meet the Proposed MY 2032 Standards Relative to the Reference Case (2021$)

	258

Table 2-98 MY 2027 Purchaser Per-ZEV Upfront Costs, Operating Costs, and Payback Period (2021$)	259

Table 2-99 MY 2032 Purchaser Per-ZEV Upfront Costs, Operating Costs, and Payback Period (2021$)	259

Table 2-100 Comparison of ZEV Technology Adoption Rates in the Technology Packages Considered for Between

the Proposed Standards and Alternative Considered	260

Table 2-101 Projected ZEV Adoption Rates for MYs 2027-2032 Technology Packages for the Alternative	260

Table 3-1: GDP Price Deflators* Used to Adjust Costs to 2021 Dollars	274

Table 3-2: Learning Curve applied to BEV, FCEV and ICE Powertrain Costs in the Reference, Proposal and

Alternative Scenarios	278

Table 3-3: Retail Price Equivalent Factors in the Heavy-Duty and Light-Duty Industries	279

Table 3-4: Fleet-Wide Incremental Technology Costs for ZEVs, Millions of 2021 Dollars*	280

Table 3-5: Battery Tax Credit in Millions of 2021 dollars *	282

Table 3-6: Total Vehicle Package RPE, Battery Tax Credits, and Manufacturer RPE (including Battery Tax Credits)
for the Proposed Option Relative to the Reference Case, All Regulatory Classes and All Fuels, Millions of 2021

dollars*	282

Table 3-7: Total Package RPE, Battery Tax Credits, and Manufacturer RPE (including Battery Tax Credits) for the
Alternative Option Relative to the Reference Case, All Regulatory Classes and All Fuels, Millions of 2021

dollars*	283

Table 3-8: Vehicle Tax Credit in Millions 2021 dollars*	284

Table 3-9: EVSE Costs, Millions 2021 dollars *	285

Table 3-10: Incremental Purchaser Upfront Costs for the Proposed Option Relative to the Reference Case for in

Millions 2021 dollars*	286

Table 3-11: Incremental Purchaser Upfront Costs for the Alternative Option Relative to the Reference Case for in

Millions 2021 dollars*	287

Table 3-12: Retail Fuel Cost Per Mile for Model Year 2027 Vehicles During the First 28 Years for each MOVES

Source Type and Regulatory Class by Fuel Type* (cents/mile in 2021 dollars, 3% discounting)	289

Table 3-13: Retail Fuel Cost Per Mile for Model Year 2027 Vehicles During the First 28 Years for each MOVES

Source Type and Regulatory Class by Fuel Type* (cents/mile in 2021 dollars, 7% discounting)	290

Table 3-14: Retail Fuel Cost Per Mile for Model Year 2027 Vehicles During the First 28 Years for each MOVES

Source Type and Regulatory Class Across All Fuel Types*	290

Table 3-15: Retail Fuel Cost Per Mile for Model Year 2027 Vehicles During the First 28 Years for each MOVES

Source Type and Regulatory Class Across All Fuel Types*	292

Table 3-16: Annual Undiscounted Pre-Tax Fuel Costs for the Proposal Relative to the Reference Case, Millions of

2021 Dollars *	292

Table 3-17: Annual Undiscounted Pre-Tax Fuel Costs for the Alternative Relative to the Reference Case, Millions of
2021 Dollars *	293

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Table 3-18: DEF Cost Per Mile for Model Year 2027 Vehicles During the First 28 Years for each MOVES Source

Type and Regulatory Class Across All Fuel Types* (cents/mile in 2021 dollars, 3% discounting)	294

Table 3-19: DEF Cost Per Mile for Model Year 2027 Vehicles During the First 28 Years for each MOVES Source

Type and Regulatory Class Across All Fuel Types*	295

Table 3-20: Annual Undiscounted DEF Costs for the Proposal relative to the Reference Case, Millions of 2021 dollars*

	296

Table 3-21: Annual Undiscounted DEF Costs for the Alternative relative to the Reference Case, Millions of 2021

dollars*	297

Table 3-22: Values for Determining Maintenance and Repair in 2019 Dollars	298

Table 3-23 Scalers of Maintenance and Repair based on Vehicle Fuel Type	298

Table 3-24: Maintenance and Repair Per Mile for Model Year 2027 Vehicles During the First 28 Years for Each
MOVES Source Type, ICE compared to BEV and FCEV Costs* (cents/mile in 2021 dollars, 3% discounting)

	299

Table 3-25: Maintenance and Repair Per Mile for Model Year 2027 Vehicles During the First 28 Years for Each

MOVES Source Type, ICE to BEV and FCEV * (cents/mile in 2021 dollars, 7% discounting)	299

Table 3-26: Maintenance and Repair Per Mile for Model Year 2027 Vehicles During the First 28 Years for Each

MOVES Source Type, for all Vehicle Types* (cents/mile in 2021 dollars, 3% discounting)	300

Table 3-27: Maintenance and Repair Per Mile for Model Year 2027 Vehicles During the First 28 Years for Each

MOVES Source Type, for all Vehicle Types* (cents/mile in 2021 dollars, 7% discounting)	300

Table 3-28: Annual Undiscounted Total Maintenance & Repair Costs for the Proposal Relative to the Reference Case,

Millions of 2021 Dollars *	301

Table 3-29: Annual Undiscounted Total Maintenance & Repair Costs for the Alternative Relative to the Reference

Case, Millions of 2021 Dollars *	301

Table 3-30: Total Package RPE Cost Impacts of the Proposed Option Relative to the Reference Case, All Regulatory

Classes and All Fuels, Millions of 2021 Dollars*	303

Table 3-31: Total Package RPE Cost Impacts of the Alternative Option Relative to the Reference Case, All Regulatory

Classes and All Fuels, Millions of 2021 Dollars*	304

Table 3-32: Total ESVE Cost in the Reference, Proposed, Alternative, Change between Proposed and Reference Case,
Change between Alternative and Reference Case; All Regulatory Classes and All Fuels, Millions of 2021

Dollars*	304

Table 3-33: Total Operating Cost Impacts of the Proposed Option Relative to the Reference Case, All Regulatory

Classes and All Fuels, Millions of 2021 Dollars*	305

Table 3-34: Total Operating Cost Impacts of the Alternative Option Relative to the Reference Case, All Regulatory

Classes and All Fuels, Millions of 2021 Dollars*	306

Table 3-35: Total Technology, Operating Cost and EVSE Cost Impacts of the Proposed Option Relative to the

Reference Case, All Regulatory Classes and All Fuels, Millions of 2021 dollars*	307

Table 3-36: Total Technology, Operating Cost and EVSE Cost Impacts of the Alternative Option Relative to the

Reference Case, All Regulatory Classes and All Fuels, Millions of 2021 dollars*	308

Table 1-1 MOVES source type definitions	311

Table 4-2 MOVES regulatory class definitions	311

Table 4-3 MOVES3.R3 Energy Efficiency Ratios for Heavy-duty Electric Vehicles	312

Table 4-4 EV Charging and Battery Efficiency Assumptions in MOVES3.R3	313

Table 4-5 ZEV sales percentage schedule in California's ACT rule	317

Table 4-6 National heavy-duty ZEV adoption in the reference case	318

Table 4-7 Comparison in ZEV adoption rates between the proposed standards and alternative	319

Table 4-8 IRA-adjusted incremental EGU emission factors used to estimate EGU emissions increases attributable to

additional HD ZEV adoption in the proposal	325

Table 4-9 2050 refinery emissions projected from 2016v2 emissions modeling platform	326

Table 4-10 Adjustment factors applied to 2050 refinery inventory	326

Table 4-11 Annual downstream heavy-duty GHG emission reductions from the proposed standards in calendar years

(CYs) 2035, 2045, and 2055	327

Table 4-12 Annual downstream heavy-duty criteria pollutant and air toxic emission reductions from the proposed

standards in calendar years (CYs) 2035, 2045, and 2055 	328

Table 4-13 Year-over-year GHG emission reductions from the proposed CO2 emission standards	328

Table 4-14 Year-over-year emission inventory reductions for the proposed CO2 emission standards for select criteria
pollutants	329

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Table 4-15 Cumulative 2027-2055 downstream GHG emission reductions from the proposed CO2 emission standards

	330

Table 4-16 Annual upstream EGU CO2 emission increases from the proposed standards in calendar years (CYs) 2035,

2045, and 2055	344

Table 4-17 Annual upstream EGU criteria pollutant emission increases from the proposed standards in calendar years

(CYs) 2035, 2045, and 2055	345

Table 4-18 Emission reductions from refineries in CY 2055 from the proposal	345

Table 4-19 Year-over-year EGU CO2 emission increases reflecting the proposed CO2 emission standards	346

Table 4-20 Year-over-year EGU emission inventory increases for criteria pollutants reflecting the proposed CO2

emission standards	346

Table 4-21 Cumulative 2027-2055 EGU CO2 emission increases from the proposed CO2 emission standards	349

Table 4-22 Annual net CO2 emission impacts3 from the proposed standards in calendar years (CYs) 2035, 2045, and

2055 	349

Table 4-23 Cumulative 2027-2055 EGU CO2 emission impacts3 (in BMT) reflecting the proposed CO2 emission

standards	349

Table 4-24 Annual net impacts3 on criteria pollutant emissions from the proposed CO2 emission standards in calendar

years (CYs) 2035 and 2045	350

Table 4-25 Net impacts3 on criteria pollutant emissions from the proposed CO2 emission standards in CY 2055 ...350

Table 4-26 Year-over-year net CO2 emission impacts3 of the proposed standards, in MMT	351

Table 4-27 Year-over-year net emission impacts3 of the proposed standards for NOx and VOC	353

Table 4-28 Year-over-year net emission impacts3 of the proposed standards for PM2.5 and SO2	355

Table 4-29 Annual downstream heavy-duty GHG emission reductions from the alternative in calendar years (CY)

2035,2045, and 2055	356

Table 4-30 Cumulative 2027-2055 downstream GHG emission reductions from the proposed emission standards and

the alternative	357

Table 4-31 Annual downstream heavy-duty criteria pollutant and air toxic emission reductions from the alternative in

calendar years (CYs) 2035, 2045, and 2055 	358

Table 4-32 Annual upstream EGU CO2 emission increases from the alternative standards in calendar years (CYs)

2035,2045, and 2055	358

Table 4-33 Cumulative 2027-2055 EGU CO2 emission increases from the proposed and alternative CO2 emission

standards	359

Table 4-34 Annual upstream EGU criteria pollutant emission increases from the alternative in calendar years (CYs)

2035,2045, and 2055	359

Table 4-35 Emission reductions from refineries in CY 2055 from the proposal and alternative	359

Table 4-36 Annual net CO2 emission impacts3 from the alternative in calendar years (CYs) 2035, 2045, and 2055360
Table 4-37 Cumulative 2027-2055 EGU CO2 emission impacts3 from the alternative compared to the proposed

standards	360

Table 4-38 Annual net impacts3 on criteria pollutant emissions from the alternative in calendar years (CYs) 2035 and

2045 	360

Table 4-39 Net impacts3 on criteria pollutant emissions from the alternative in CY 2055	360

Table 6-1 Estimated U.S. Oil Import Reductions and Electricity Consumption Increases due to the Proposal *	430

Table 6-2 Fossil Fuel Reductions due to the Proposal, Millions of gallons	431

Table 7-1 Interim Social Cost of Carbon Values, 2027-2055 (2021$/Metric Ton CO2)	440

Table 7-2 Interim Social Cost of Carbon Values, 2027-2055 (2021 $/Metric Ton CH4)	441

Table 7-3 Interim Social Cost of Carbon Values, 2027-2055 (2021 $/Metric Ton N2O)	442

Table 7-4 Benefits of Reduced CO2 Emissions from the Proposal, Millions of 2021 dollars	447

Table 7-5 Benefits of Reduced CH4 Emissions from the Proposal, Millions of 2021 dollars	448

Table 7-6 Benefits of Reduced N2O Emissions from the Proposal, Millions of 2021 dollars	448

Table 7-7 Benefits of Reduced GHG Emissions from the Proposal, Millions of 2021 dollars	449

Table 7-8 Human Health Effects of PM2.5	453

Table 7-9 PM2.5-related Benefit Per Ton values (2021$) associated with the reduction of NOx, SO2 and directly emitted
PM2.5 emissions for (A) Onroad Heavy-Duty Diesel Vehicles, (B) Onroad Heavy-Duty Gasoline Vehicles, and

(C) Electricity Generating Units	457

Table 7-10 Summary of the estimated tons of reduced NOx, SO2 and direct PM2.5 per year from Heavy-Duty Diesel
Vehicles and the associated monetized PM2.5-related health benefits (millions, 2021$) for the proposed program
	458

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T able 7-11 Summary of the estimated tons of reduced NOx, SO2 and direct PM2.5 per year from Heavy-Duty Gasoline
Vehicles and the associated monetized PM2.5-related health benefits (millions, 2021$) for the proposed program

	458

Table 7-12 Summary of the estimated tons of reduced NOx, SO2 and direct PM2.5 per year from Heavy-Duty Diesel
Vehicles and the associated monetized PM2.5-related health benefits (millions, 2021$) for the alternative

program	459

T able 7-13 Summary of the estimated tons of reduced NOx, SO2 and direct PM2.5 per year from Heavy-Duty Gasoline
Vehicles and the associated monetized PM2.5-related health benefits (millions, 2021$) for the alternative

program	460

Table 7-14 Year-over-year monetized PM2.5-related health benefits of Heavy-Duty Diesel and Heavy-Duty Gasoline

Vehicles (millions, 2021$) for the proposed program	460

Table 7-15 Year-over-year monetized PM2.5-related health benefits of Heavy-Duty Diesel and Heavy-Duty Gasoline

Vehicles (millions, 2021$) for the alternative program	461

Table 7-16 Summary of the estimated tons of increased NOx, SO2 and direct PM2.5 per year from EGUs and the

associated monetized PM2.5-related health impacts (millions, 2021$) for the proposed program	462

Table 7-17 Summary of the estimated tons of increased NOX, S02 and direct PM2.5 per year from EGUs and the

associated monetized PM2.5-related health impacts (millions, 2021$) for the alternative program	463

Table 7-18 Year-over-year monetized PM2.5-related health benefits (millions, 2021$) of Onroad Heavy-Duty Vehicle

emissions, increased emissions from EGUs and net benefits from the proposed program	464

Table 7-19 Year-over-year monetized PM2.5-related health benefits (millions, 2021$) of Onroad Heavy-Duty Vehicle

emissions, increased emissions from EGUs, and net benefits from the alternative program	464

Table 7-20 Unquantified Criteria Pollutant Health and Welfare Benefits Categories	466

Table 7-21 Projected Trends in U.S. Oil Exports/Imports, Net Refined Petroleum Product Exports, Net Crude
Oil/Refined Petroleum Product Exports, Oil Consumption and U.S. Oil Import Reductions Resulting from the

Proposal for Selected Years from 2027 to 2055 (Million)	480

Table 7-22: Macroeconomic Oil Security Premiums for Proposal from 2027-2055 (2021$/Barrel)*	483

Table 7-23 Energy Security Benefits from the Proposal (millions of 2021 dollars)	485

Table 8-1 Vehicle-Related Technology Costs Associated with the Proposal and Alternative, Millions of 2021 dollars

	493

Table 8-2 Vehicle-Related Operating Savings Associated with the Proposal and Alternative, Millions of 2021 dollars

*	493

Table 8-3 Energy Security Benefits Associated with the Proposal and Alternative, Millions of 2021 dollars	493

Table 8-4 Climate Benefits from Reduction in GHG Emissions Associated with the Proposal and Alternative, Millions

of 2021 dollars	494

Table 8-5 PM2.5-related Emission Reduction Benefits Associated with the Proposal and Alternative, Millions of 2021

dollars	494

Table 8-6 Net Benefits Associated with the Proposal and Alternative, Millions of 2021 dollars	495

Table 8-7 Transfers Associated with the Proposal and the Alternative, Millions of 2021 dollars	496

Table 9-1 Primary Small Business NAICS Categories Affected by this Proposal	498

Table 9-2 Summary of Small Entity Impacts	500

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List of Figures

Figure 1-1 Total Weight of Shipments by Transportation Mode	2

Figure 1-2 Value of Freight Moved Between the U.S., Canada, and Mexico	4

Figure 1-3 2021 HD Sales Percentages by AEO Categories	11

Figure 1-4 AEO 2022 Sales Percent by Weight Class and Energy Use for 2021 and 2050	12

Figure 1-5 Complete Coach Works' process for repowering conventional buses to battery electric buses	40

Figure 1-6 Spartan Emergency Response places the battery packs of their Vector fire truck strategically to improve

handling	41

Figure 1-7 Bollinger Motors' commercial electric trucks, (a) Cab-forward design increases cargo space over
conventional cabs, (b) Platform enables the trucks to be upfit to fill a wide variety of purposes, (c) Battery packs

in the ladder frame are flexible enough	42

Figure 1-8 Heavy-Duty Electric Trucks Available in the U.S. by Model Year	44

Figure 1 -9 Example charging station with four EVSE ports and six connectors	61

Figure 1-10 Private Fleet Level 2 and DCFC Ports by Fleet Type (Data Source: Alternative Fuels Data Center Station

Locator, Second Quarter 2022, from NREL report)	65

Figure 1-11 U.S. Department of Energy's H2@Scale Concept	79

Figure 1-12 DOE Comparison of Domestic Hydrogen Production Pathways	80

Figure 2-1 Change in VMT Over Time for HD Vehicles	120

Figure 2-2 Direct Manufacturing Cost of a Diesel Engine as a Function of Engine Power59	143

Figure 2-3 M&R Cost Per Mile (2021$/mi)	157

Figure 2-4 Modeled HVAC Power Demand of a Class 8 Transit Bus as a Function of Ambient Temperature	161

Figure 2-5 MOVES National VMT Distribution as a Function of Temperature for 2b-8 HD Vehicles	162

Figure 2-6 Modeled Power Demand for Battery Conditioning for Class 8 Transit Bus with a 300 kWh Battery	164

Figure 2-7 Assumptions for battery tax credit from IRA Section 13502	173

Figure 2-8: Electric Drive Component Costs from Nair et. al	175

Figure 2-9 Projection of Cost Target for Market Competitiveness of Hydrogen	193

Figure 4-1 Weekday and weekend charging profiles for HD BEVs in the control case	323

Figure 4-2 Cumulative and yearly emission reductions for C02e from the proposed standards from 2027 through 2055

	330

Figure 4-3 Yearly methane inventory for the reference case and the proposed emission standards from 2027 through

2055 	331

Figure 4-4 Yearly N2O inventory for the reference case and the proposed emission standards from 2027 through 2055

	332

Figure 4-5 Yearly C02e inventory for the reference case and the proposed emission standards from 2027 through 2055

	333

Figure 4-6 Yearly NOx inventory for the reference case and the proposed emission standards from 2027 through 2055

	334

Figure 4-7 Yearly primary exhaust PM2.5 inventory for the reference case and the proposed emission standards from

2027 through 2055 	335

Figure 4-8 Yearly VOC inventory for the reference case and the proposed emission standards from 2027 through 2055

	336

Figure 4-9 CO2 reductions from the proposed standards by regulatory class and source type for calendar years (CY)

2035,2045, and 2055	337

Figure 4-10 Methane reductions from the proposed standards by regulatory class, source type, and fuel type for CYs

2035,2045, and 2055	338

Figure 4-11 NOx reductions from the proposed standards by regulatory class, source type, and fuel type for CYs 2035,

2045, and 2055	340

Figure 4-12 Primary exhaust PM2.5 reductions from the proposed standards by regulatory class, source type, fuel type,

and emission process for CY 2035, 2045, and 2055	341

Figure 4-13 VOC reductions from the proposed standards by regulatory class, source type, and fuel type for CYs 2035,

2045, and 2055	343

Figure 4-14 Yearly CO2 emissions changes from EGUs from the proposed CO2 emission standards from 2027 through

2055 	348

Figure 4-15 Yearly criteria pollutant emissions increases from EGUs from the proposed CO2 emission standards from
2027 through 2055	348

x

-------
Figure 4-16 Year-over-year net CO2 emission impacts of the proposed standards from 2027 through 2055 	351

Figure 4-17 Year-over-year net NOx emission impacts of the proposed standards from 2027 through 2055	352

Figure 4-18 Year-over-year net VOC emission impacts of the proposed standards from 2027 through 2055	353

Figure 4-19 Year-over-year net PM2.5 emission impacts of the proposed standards from 2027 through 2055 	354

Figure 4-20 Year-over-year net SO2 emission impacts of the proposed standards from 2027 through 2055	355

Figure 4-21 Yearly CChe inventory for the reference case, proposed standards, and alternative from 2027 through

2055 	357

Figure 4-22 Comparison of net C02 emission impacts of the proposal and alternative from 2027 through 2055....361

Figure 6-1 Workers per million dollars in sales, adjusted for domestic production	425

Figure 7-1 Frequency Distribution of SC-C( > • Estimates for 2030	443

Figure 7-2 Frequency Distribution of SC-CII: Estimates for 2030	444

Figure 7-3 Frequency Distribution of SC-\ •( > Estimates for 2030	444

Figure 7-4 U.S. Tight Oil Production by Producing Regions (in MMBD) and West Texas Intermediate (WTI) Crude
Oil Spot Price (in U.S. Dollars per Barrel), Source: 1:1 A 	475

xi

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Executive Summary

The Environmental Protection Agency (EPA) is proposing new GHG standards for heavy-
duty highway (hereafter referred to as "heavy-duty" or HD) vehicles to further reduce GHG
emissions. Despite the significant emissions reductions achieved by previous rulemakings, GHG
emissions from HD vehicles continue to impact public health, welfare, and the environment.

This Draft Regulatory Impact Analysis (DRIA) contains supporting documentation for the
EPA proposed rulemaking and addresses requirements in Clean Air Act Section 317 and
requirements under Executive Order (E.O.) 12866 to estimate the benefits and costs of major
new pollution control regulations. The preamble to the Federal Register notice associated with
this document provides the full context for the EPA proposed rule, including statutory and
executive order reviews in Section XI, and it references this DRIA throughout. This document
contains the following Chapters:

Chapter 1 Industry Characterization and Technologies to Reduce Greenhouse Gas
Emissions

This chapter provides an overview of the HD industry, an overview of GHG-reducing
technologies, and market information for each of the affected industries for background
information purposes. To assess the impacts of GHG regulations upon the affected industries, it
is important to understand the nature of the industries impacted by the regulations. These
industries include the manufacturers of Class 2b/3 incomplete vehicles through Class 8 trucks,
engines, and on-road equipment. Users of these vehicles, including large fleets and corporations,
have become increasingly interested in incorporating zero-emission vehicles (ZEVs) into their
operations. To meet this demand, many highway HD vehicle manufacturers and suppliers have
been conducting research on BEVs and hydrogen fuel cell electric vehicles (FCEVs). Initial
vehicles from this research investment are now entering the market. Adoption of these ZEVs
requires the establishment of HD vehicle charging and hydrogen refueling infrastructure.

Chapter 2 Technology Assessment

This chapter describes the operational characteristics and costs that we used to estimate HD
ZEV technology feasibility and adoption rates that form the technology package that supports the
calculated proposed standards for MYs 2027 through 2032. To conduct the analysis, EPA
developed a flexible spreadsheet-based framework called the Heavy-Duty Technology Resource
Use Case Scenario (HD TRUCS) tool.

HD TRUCS evaluates the design features needed to meet the energy and power demands of
various HD vehicle types when using ZEV technologies. To build technology packages using
HD TRUCS, we created 101 representative vehicles in HD TRUCS that cover the full range of
weight classes within the scope of the proposed standards (Class 2b through 8 vocational
vehicles and tractors). The representative vehicles cover many aspects of work performed by the
industry. This work was translated into total energy and power demands per vehicle type based
on everyday use of HD vehicles, ranging from moving goods and people to mixing cement. We
then identified the technical properties and costs required for a BEV or FCEV to meet the
operational needs of a comparable internal combustion engine (ICE) HD vehicle.

xii

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Chapter 3 Program Costs

This chapter presents estimates of the technology package, manufacturer, consumer, and
social costs. In addition, the manufacturer and consumer cost analyses quantitatively include two
tax credits from the Inflation Reduction Act as appropriate, specifically the battery tax credit
under section 13502 (for both manufacturer and consumer costs) and the vehicle tax credit under
section 13403 (for consumer costs). The technology package costs are presented as direct
manufacturing costs and associated indirect costs, which together represent the estimated costs
incurred by manufacturers (i.e., regulated entities) to comply with the proposed standards. The
analysis also includes estimates of electric vehicle supply equipment (EVSE) costs and the
operating costs associated with HD ICE vehicles, BEVs, and FCEVs. These EVSE and operating
costs do not represent compliance costs for manufacturers, but rather estimated costs incurred by
users and society more generally of MY 2027 and later HD vehicles.

Chapter 4 Emission Inventories

This chapter presents our analysis of the national emissions impacts of GHG from the
proposal and alternative for calendar years 2027 through 2055 from both downstream and some
upstream sources. We estimated onroad downstream national inventories using an updated
version of EPA's Motor Vehicle Emission Simulator (MOVES) model (MOVES3.R3). This
chapter also presents our analysis of the national emissions impacts of the proposal and
alternative for some upstream emissions sources, including emissions from electricity generation
units (EGUs) that result from increased energy demand from HD ZEVs as modeled using the
Integrated Planning Model (IPM). In addition, this chapter presents our estimate of the proposal
and alternative's impacts on refinery emissions. This analysis uses adjustments to the 2050
inventory based on some assumptions about how refinery activity will change in response to
lower demand for liquid fuel.

Chapter 5 Health and Environmental Impacts

This chapter presents a discussion of the climate change impacts of GHGs; health and
environmental effects associated with exposure to ambient concentrations of non-GHG
pollutants; as well as environmental justice impacts from the emissions changes associated with
the proposal. The discussion of health impacts is mainly focused on describing the effects of air
pollution on the population in general. Additionally, children are recognized to have increased
vulnerability and susceptibility related to air pollution and other environmental exposures; this
and effects for other vulnerable and susceptible groups are discussed in this chapter.

Chapter 6 Economic and Other Impacts

This chapter discusses potential impacts of the proposed rule on vehicle sales including
potential shifts among modes and classes of vehicles, and between domestic and foreign sales. It
also discusses the acceptance of ZEVs by HD purchasers and the potential for rebound effects on
vehicle miles traveled. This chapter then discusses the potential impacts of the proposed rule on
employment. Finally, this chapter discusses the impacts of the proposed rule on U.S. oil imports
and electricity consumption.

Chapter 7 Benefits

xiii

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This chapter describes benefits attributable to the proposed rule from three sources: climate
benefits, criteria pollutant health benefits, and energy security benefits. We estimate the social
benefits of GHG reductions expected to occur as a result of the proposed standards using
estimates of the social cost of greenhouse gases (SC-GHG), specifically using the social cost of
carbon (SC-CO2), social cost of methane (SC-CH4), and social cost of nitrous oxide (SC-N2O).
We monetize the economic benefits from improvements in human health resulting from criteria
pollutant emissions reductions using PIVh.s-related benefit-per-ton values. This chapter also
describes energy security impacts, including monetized benefits, associated with an expected
reduction in demand for liquid fuels.

Chapter 8 Net Benefits

This chapter compares the estimated range of total benefits to total costs associated with the
proposal and the alternative. Benefits include those associated with reductions of GHGs,
monetized health benefits from reductions in PM2.5, energy security benefits, fuel savings, and
vehicle-related operated savings. Total costs include costs for both new technology and the
operating costs associated with that new technology. The chapter presents three different
methods for comparing benefits to costs.

Chapter 9 Small Business Analysis

This chapter presents an analysis of the potential impacts of the proposed rule on small
entities that would be subject to the HD vehicle provisions of this proposed rule. The small
businesses considered in this analysis include manufacturers of the following types: heavy-duty
conventional vehicles and heavy-duty electric vehicles. The analysis estimates that no small
entities in these manufacturer categories will experience an impact of 3% or more of their annual
revenue as a result of our proposed rule.

xiv

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Chapter 1 Industry Characterization and Technologies to Reduce GHG

Emissions

1.1 Introduction

To assess the impacts of the proposed greenhouse gas (GHG) regulations upon the affected
industries, it is important to understand the nature of the industries impacted by the regulations.
These industries include the manufacturers of Class 2b/3 incomplete vehicles1 through Class 8
trucks, engines, and on-road equipment. Users of these vehicles, including large fleets and
corporations, have become increasingly interested in incorporating zero emissions vehicles
(ZEVs) into their operations. To meet this demand, many highway heavy-duty (HD) vehicle
manufacturers and suppliers have been conducting research on battery electric vehicles (BEVs)
and hydrogen fuel cell electric vehicles (FCEVs). Initial vehicles from this research investment
are now entering the market. Adoption of these ZEVs requires the establishment of HD vehicle
charging and hydrogen refueling infrastructure. This chapter provides an overview of the heavy-
duty industry, an overview of GHG-reducing technologies, and market information for each of
the affected industries for background information purposes.

1.2 Heavy-duty Vehicle Industry

Heavy-duty vehicles perform many different types of work including moving people and
goods, cleaning streets, and providing access to fix utilities. Here we focus on the size of the
goods-moving market to highlight the importance and impact of the sector.

1.2.1 Freight Work Performed by and Operation of Heavy-duty Trucks

In 2019, heavy-duty trucks carried 70 percent of all freight moved in the U.S. by tonnage and
73 percent by value in the U.S, and heavy-duty trucks are expected to move freight at an even
greater rate in the future. According to the U.S. Department of Transportation's (DOT's) Federal
Highway Administration (FHWA), the U.S. transportation system moved, on average, an
estimated 51 million tons of goods worth an estimated $52 billion (in U.S. 2012$) per day in
2018, or over 18 billion tons of freight worth more than $18 trillion in the year 2018. Of this,
heavy-duty trucks moved over 11 billion tons of freight worth an estimated $11 trillion in 2018,
or an average of nearly 31 million tons of freight worth $32 billion per day. The FHWA's 2018
Freight Analysis Framework estimates that this tonnage will increase about 1.2 percent per year
through 2045, and that the value of the freight moved is increasing faster than the tons

1 Complete heavy-duty vehicles at or below 14,000 lbs. GVWR are chassis-certified under 40 CFR part 86, while
incomplete vehicles at or below 14,000 lbs. GVWR may be certified to either 40 CFR part 86 (meeting standards
under subpart S) or 40 CFR part 1037 (installed engines would then need to be certified under 40 CFR part 1036).
Class 2b and 3 vehicles are primarily chassis-certified complete commercial pickup trucks and vans. We intend to
pursue a combined light-duty and medium-duty rulemaking to set more stringent standards for complete and
incomplete vehicles at or below 14,000 lbs. GVWR that are certified under 40 CFR part 86, subpart S. The standards
proposed in this rule would apply for all heavy-duty vehicles above 14,000 lbs. GVWR, except as noted in 40 CFR
1037.150(1). The proposed standards in this rule would also apply for incomplete heavy-duty vehicles at or below
14,000 lbs. GVWR if vehicle manufacturers opt to certify those vehicles under 40 CFR part 1037 instead of
certifying under 40 CFR part 86, subpart S.

-------
transported. Figure 1-1 shows the total tons of freight moved by each mode of freight
transportation in 2017, 2019, and projections for 2050.1

¦	2017

¦	2019

¦	2050

III 111 „ III III

Rail Water Air other, Multiple Pipeline
Unknown Modes

Figure 1-1 Total Weight of Shipments by Transportation Mode

According to the 2020 Highway Statistics published by the U.S. FHWA,2 in 2019 there were
just over 2.9 million combination tractors (e.g. Class 7 and 8) registered in the U S out of a total
of over 13 million trucks of all types (private and commercial) registered in the U.S. Table 1-1
presents the number of trucks compared to the number of vessels and other modes of
transportation that move freight.2

Table 1-1 Number of U.S. Vehicles, Vessels, and Other Conveyances: 1990-2019

Mode of
Transportation

Classification

1990

2000

2010

2015

2019

Highway

Trucks

6,195,876

8,022,648

10,770,054

11,203,184

13,095,643

Trucks, single-
unit 2-axle 6-tire
or more

4,486,981

5,926,030

8,217,189

8,456,302

10,160,433

Trucks,
combination

1,708,895

2,096,619

2,552,865

2,746,882

2,925,210

Total highway
vehicles

193,057,376

225,821,241

250,070,046

263,610,219

276,491,174

Rail

Locomotive,
Class 1

18,835

20,028

23,893

26,574

24,597

Freight cars, total

1,212,261

1,380,796

1,309,029

1,609,052

1,675,511

Freight cars,
Class

658,902

560,154

397,730

330,996

270,378

Freight cars,
Nonclass

103,527

132,448

101,755





Freight cars, car
companies and
shippers

449,832

688,194

809,544





20000
18000
16000
14000

C

£ 12000
S 10000

c

J 8000
6000
4000
2000
0

Truck

2

-------
Water

Nonself-propelled
vessels

33,597

31,372

30,265

31,748

33,329

Self-propelled
vessels

8,236

9,293

9,618

9,043

9,928

Total vessels

41,833

40,665

39,883

40,791

43,257

According to the FHWA "Freight Facts and Figures 2017, 3 trucks move more than 60
percent of all hazardous materials shipped within the U.S.; however, truck ton-miles11 of
hazardous shipments account for only about 33 percent of all transportation ton-miles due to the
relatively short distances these materials are typically carried by trucks. Trucks move this freight
an average of 63 miles per shipment whereas rail shipments travel an average of 640 miles per
trip. In terms of growing international trade, trucks are the most common mode used to move
imports and exports between both borders and inland locations. Table 1-2 shows the tons and
value moved by truck compared to other transportation methods.

Table 1-2 Domestic Mode of Exports and Imports by Tonnage and Value from 2012-2045 3

Domestic
Mode

Tons (thousands)

Value (millions of 2012 $)

2012

2020

2045

2012

2020

2045

Grand Total

2,057,833

2,479,699

4,540,300

3,764,477

5,265,375

14,595,630

Truck

807,077

985,757

2,188,843

1,964,961

2,679,834

7,782,009

Rail

315,760

342,393

661,910

310,757

413,456

962,844

Water

156,140

199,892

333,216

160,235

222,772

531,973

Air
(including
truck-air)

5,355

7,138

22,120

538,275

835,816

2,883,803

Multiple
modes and
mail

109,251

134,851

368,665

375,541

537,949

1,576,807

Pipeline

359,021

582,716

708,596

174,962

324,515

354,333

Other and
unknown

4,740

6,076

15,962

38,855

105,330

324,385

No domestic
mode

300,489

220,875

240,988

200,892

145,704

159,477

Conversely, transportation of foreign trade is dominated by movement via water with trucks
hauling approximately 12 percent of imported freight followed by pipeline and rail. As of 2019,
Mexico was the top trading partner with the U.S. in terms of the value of the merchandise traded
($547 billion in U.S. 2012$), Canada was second ($545 billion in U.S. 2012$), China was third
($497 billion in U.S. 2012$). Truck traffic is the most heavily utilized transportation mode from
the two North American trade partners, Mexico and Canada. As of 2020, over 68 percent of the
value and over 19 percent of the total imported and exported freight moved between the U.S.,
Canada, and Mexico was hauled by truck, as shown in Figure 1-2.4

11A ton-mile is the equivalent of moving one ton of product one mile.

3

-------
800

2S0

Air Other Pipeline Rail Truck Water

Value (billions of current U.S. dollars) 1 ~ ¦ Weight (millions of short tons)

Figure 1-2 Value of Freight Moved Between the U.S., Canada, and Mexico
1.2.2 Existing Heavv-Duty Truck Market Benchmarking

The heavy-duty vehicle segment is a dynamic industry that includes a variety of types of
vehicles and possible configurations. This proposed program would address heavy-duty vehicles
that fall into the following regulatory categories established by EPA: vocational vehicles in
Classes 2b-8 and tractors in Classes 7 and 8.

Class 2b and 3 vocational vehicles at issue in this proposed program include certain
incomplete111 pickups, incomplete vans, and vocational vehicles such as heavy-duty work truck-
type pickups and related van-type vehicles that are in a limited build configuration and ready to
receive final outfitting by body building companies. The latter case involves the manufacture of
vehicles that may be used for a variety of commercial purposes, including use as ambulances,
shuttle buses, etc. Class 4-8 vocational vehicles encompass a wide range of heavy-duty vehicles
such as delivery trucks, school buses, etc. Combination tractors typically operate as either short-
haul or long-haul trucks. Combination tractors are designed either with sleeping quarters (sleeper
cab) or without sleeping quarters (day cab). Generally, day cab tractors are used to haul trailers
over shorter distances, typically into metropolitan areas. Sleeper cab tractors generally haul
trailers longer distances between cities and states with trips well over 1,000 miles in length.

To understand the existing heavy-duty industry, we performed an analysis of current internal
combustion engine (ICE) powered heavy-duty vehicles in the market and their capabilities to
generate typical power requirements and rates of energy consumption. This information was then
used to help inform our initial decisions on technical feasibilities of zero-emission vehicle (ZEV)

111 As explained and defined in 40 CFR 1037.801, the primary use of the term "incomplete vehicle" is to distinguish
whether a vehicle is complete when it is first sold as a vehicle, where an incomplete vehicle is defined as not a
complete vehicle and a complete vehicle is defined as a functioning vehicle that has the primary load carrying
device or container (or equivalent equipment) attached. Incomplete vehicles may also be cab-complete vehicles.

-------
technologies™ to include in the technology packages for the proposed program using an
internally developed tool discussed in detail in DRIA Chapter 2.

We selected 76 ICE vehicles that represent much of the heavy-duty industry and that also had
similar ZEV options available in MY 2021. Some of these vehicle types can be used for multiple
duty cycles. Table 1-3 lists the publicly available information collected to benchmark basic
powertrain and performance criteria including make; model; vehicle type; weight class; fuel
type; engine manufacturer, model, displacement, mass, power, and torque; transmission make,
model, and mass; fuel tank size; mass of fuel; Diesel Exhaust Fluid (DEF) tank size; mass of
DEF; total mass of the engine, transmission, fuel, and DEF; vehicle minimum wheelbase; and
vehicle width.

lv We use the term ZEV to refer to technologies that result in zero tailpipe emissions. Example ZEV technologies
include battery electric vehicles and fuel cell vehicles.

5

-------
Table 1-3 Benchmarked Conventional Vehicles with Similar ZEV Options

Vehicle
Width

(m)

2.4

2.6

Mln.
Wheel-
base
(m)

4.3

3.6

3.5

5.5

4.3

5..6

Total
System
Mass
(kg)

551

593

1153

1359

1171

536

1452

1066

1452

1066

1040

1324

1040

1324

1040

DEF

Mass
(kg)

232

Tank
Size (L)

Fuel

Mass
(kg)

129

193

159

386

258

Tank
Size (L)

254

LZZ

235

-------
Vehicle

Width

(m)

2.6

-------
Vehicle
Width

(m)

2.6

2.4

2.5

2.6

2.5

Min.
Wheel-
base
(m)

2.9

2.8

4.5

3.3

Total
System
Mass
(kg)

2051

1892

1533

825

318

536

656

1072

1008

642

1040

1288

298

DEF

Mass
(kg)

Tank
Size (L)

Fuel

Mass
(kg)

322

193

229

290

225

214

258

298

Tank
Size (L)

379

LZZ

-------
Vehicle

Width

(m)

Peterbilt47

Peterbilt49

-------
Vehicle
Width

(m)

2.4

2.3

2.5

Min.
Wheel-
base
(m)

3.5

2.9

Total
System
Mass
(kg)

1619

1390

2051

539

485

1671

1828

1036

DEF

Mass
(kg)

Tank
Size (L)

Fuel

Mass
(kg)

322

Tank
Size (L)

379

189

Type

Diesel

Transmission

Mass
(kg)

299

324

297

Model

Endurant

RT13

3500

MFR

Eaton

Allison

Engine

Torque
(Nm)

2305

1695

2779

895

2102

2508

895

Power
(kW)

339

336

421

179

194

317

373

194

Mass
(kg)

998

769

1430

539

485

1025

1182

485

Disp

(L)

801

00
00

rsi
Lfl

O
j>
o

&
o

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1.2.3 Heavy-duty Vehicle Sales

The U.S. Energy Information Administration's (EIA's) Annual Energy Outlook (AEO) sales
estimates1 from the 2022 AEO report ("AEO 2022")54 were used to characterize sales in the
HDY market. The overall vehicle class sales percentages for calendar year (CY) 2021 are shown
in Figure 1-3. Total heavy-duty sales in 2021 were over 750,000 units, with 36.1 percent
belonging to Class 3 vehicles (including complete and incomplete), 25.9 percent belonging to
Class 4-6 vehicles, and 38.1 percent belonging to Class 7-8 vehicles. Comparatively, by 2050
projected sales for Class 3 heavy-duty vehicles (including complete and incomplete) will
increase to 43.5 percent while Class 4-6 sales will increase to 32 percent and Class 7-8 vehicles
will decrease to 24.5 percent, see Figure 1-3.

ioo.o%

90.0% f . ~>A COL

,c ™ 33 2% 30.7% 28.6% 26.4% -4.5%

80-0% 38.1% 36.2%

I 70.0% ^_ Bj

lllllll

2021 2025 2030 2035 2040 2045 2050
¦ Class 3 ¦ Class 4-6 Class 7-8

Figure 1-3 2021 HD Sales Percentages by AEO Categories54

As shown in Figure 1-4, AEO 2022 estimates for the full range of Class 3 vehicles show less
than 1 percent of 2021 sales are BEVs while fuel cell electric vehicles (FCEV) have no sales, and
hybrid and alternate fuel vehicles make up less than 1 percent of sales. AEO 2022 estimates
Class 4-6 vehicles BEV and FCEV sales comprise less than 1 percent of total sales in 2021.
Hybrid sales also are estimated to make up less than 1 percent of sales while flex fuel vehicles
make up 3.8 percent of vehicle sales in 2021 for Class 4-6 vehicles. AEO 2022 estimates for
Class 7-8 vehicles are that BEV and FCEV sales make up less than 0.1 percent, hybrid sales are
less than 0.2 percent of sales, and alternate fuel vehicles are 1.8 percent of sales in 2021.

AEO 2022 estimates for 2050 show that for Class 3 vehicles, BEVs will still make up less
than 1 percent of sales while FCEVs will still have no sales, as shown in Figure 1-4. Hybrid
vehicles are estimated to make up less than 1 percent of sales and alternate fuel vehicles make up
2.5 percent of sales in 2050 for Class 3 vehicles. For Class 4-6 vehicles in 2050, BEV sales are
estimated in AEO 2022 to still be less than 1 percent of total sales as are FCEVs, as shown in

v Although AEO sales estimates for heavy-duty vehicles do not include buses, RVs, and emergency vehicles, the
sales estimates are still useful in predicting trends in the heavy-duty market by overall percentage of new vehicle
sales in different weight classes as well as percentage of new vehicle sales by energy type.

-------
Figure 1-4. In 2050, hybrid sales are estimated to still make up less than 1 percent of sales while
alternate fuel vehicles are estimated to increase to 8.8 percent of vehicle sales for Class 4-6
vehicles. For Class 7-8 vehicles, AEO 2022 estimates that BEV and FCEV sales will continue to
make up less than 0.3 percent of sales in 2050, as shown in Figure 1-4. In 2050, hybrid sales are
expected to be less than 0.5 percent of sales and alternate fuel vehicles are expected to increase
to 4.9 percent of sales for Class 7-8 vehicles.

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%

nn%

0,0%
- 0.2%

¦ FCEV

¦ Gas Hybrid

¦ Diesel Hybrid

¦ BEV

¦ Flex Fuel
a CNG

¦ Propane

¦ Gasoline

¦ Diesel

Class 3

Class 4-6
2050

Class 7-8

Figure 1-4 AEO 2022 Sales Percent by Weight Class and Energy Use for 2021 and 2050

Table 1-4 contains the raw values of projections from AEO 2022.-- Their projections do not
include any assumptions for new regulations beyond those established by November 2021.V1 The
Bipartisan Infrastructure Law is included in AEO 2022 as it was passed in November of 2021,
whereas the Inflation Reduction Act was passed in August of 2022 and is not included in AEO
2022. Note that the projections show increased purchase of gasoline-powered vehicles relative to
diesel-powered vehicles due to lower initial vehicle prices and lower maintenance costs when
compared to diesel-powered vehicles.56 The 2050 Class 3-6 vehicle sales are 1.4 times the 2022
sales levels and for Classes 7-8 include about a 25 percent decrease in sales relative to 2021
levels. Alternate fuel vehicles are also projected to increase from 2022 to 2050 with a 1.3 times
increase for Class 3, a 2.5 times increase for Classes 4-6, and a 2.1 times increase for Classes 7-
8. Hybrids increase 3.3 times for Class 3, 3.4 times for Classes 4-6, and 1.8 times for Classes 7-
8. Fuel cells are not seen as a solution for Class 3 vehicles but are expected to increase 3.4 times
for Classes 4-6 and 1.8 times for Classes 7-8, from 2022 to 2050.

VI For example, California has adopted the Advanced Clean Truck (ACT) Regulation, which includes a manufacturer
requirement for zero-emission truck sales. ACT is not included in AEO 2022. EPA granted the ACT rule waiver
requested by California under CAA section 209(b) on March 30, 2023. 88 FR 20688, April 6, 2023 (signed by the
Administrator on March 30, 2023).

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Table 1-4: AEO 2022 Sales Projections in Thousands by Weight Class and Energy Use from 2022 - 2050

Heavy Duty Vehicle Sales (thousands)

Weight

Class 3

Class 4-6

Class 7 and 8

Class

Year

2022

2030

2040

2050

2022

2030

2040

2050

2022

2030

2040

2050

Diesel

184.138

184.462

177.589

173.916

139.453

145.676

159.266

179.699

285.648

253.274

227.757

205.417

Gasoline

83.753

112.470

155.882

201.602

53.211

58.133

65.545

79.681

0.485

0.429

0.389

0.360

Propane

0.389

0.544

0.823

1.251

0.257

0.346

0.527

0.822

0.195

0.175

0.182

0.213

Compressed

0.146

0.156

0.190

0.325

0.685

0.621

0.691

0.904

3.956

2.916

4.176

9.097

Natural Gas

Flex Fuel

4.543

4.035

4.354

5.439

7.783

8.829

12.718

19.383

0.000

Battery

0.003

0.004

0.016

0.008

0.004

0.003

0.001

Electric

Diesel

0.444

0.621

0.939

1.428

0.337

0.453

0.691

1.099

0.256

0.287

0.350

0.435

Hybrid

Gasoline

0.448

0.628

0.950

1.444

0.308

0.414

0.631

0.984

0.285

0.320

0.390

0.486

Hybrid

Fuel Cell

0.000

0.515

0.693

1.056

1.647

0.320

0.359

0.438

0.545

1.3 Current Regulations and Federal Support for Reducing Heavy-Duty Vehicle GHG
Emissions

In this section, we discuss the EPA greenhouse gas emission regulations for heavy-duty
engines and vehicles, recent Federal Government legislation to support reductions in greenhouse
gas emissions, and the California Air Resources Board's Advanced Clean Trucks program.

1.3.1 Current EPA GHG Emission Standards for Heavv-Dutv Vehicles and Engines

The Heavy-Duty Greenhouse Gas Phase 2 ("HD GHG Phase 2") program sets CO2 standards
separately for vehicles and engines. The phase in of the standards began in MY 2021 followed
by more stringent standards in MY 2024 and MY 2027. The existing heavy-duty vehicle (HDV)
emission standards are sub-categorized within the following groups: Vocational Vehicles
(segmented as specified in Table 1-5), Custom Chassis (segmented as specified in Table 1-6),
and Class 7 and Class 8 Tractors (segmented as specified in Table 1-7). The vehicle emission
standards proposed in this rulemaking would follow the vehicle classification used in the HD
GHG Phase 2 CO2 emission standards as defined in 40 CFR 1037.140.

Table 1-5 Existing Phase 2 CO2 Standards for Model Year (MY) 2027 and Later Vocational Vehicles (g/ton-

mile)57

Engine Cycle

Vehicle size

Multi-purpose

Regional

Urban

Compression-ignition

Light HDV

330

291

367

Compression-ignition

Medium HDV

235

218

258

Compression-ignition

Heavy HDV

230

189

269

Spark-ignition

Light HDV

372

319

413

Spark-ignition

Medium HDV

268

247

297

Table 1-6: Existing Phase 2 Custom Chassis CO2 Emission Standards for Model Year (MY) 2027 and Later

(g/ton-mile)57

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Vehicle Type

Assigned vehicle service class

MY 2027+

School bus

Medium HDV

271

Motor home

Medium HDV

226

Coach bus

Heavy HDV

205

Other bus

Heavy HDV

286

Refuse hauler

Heavy HDV

298

Concrete mixer

Heavy HDV

316

Mixed-use vehicle

Heavy HDV

316

Emergency vehicle

Heavy HDV

319

Table 1-7: Existing Phase 2 CO2 Standards for Model Year (MY) 2027 and Later Class 7 and Class 8

Tractors (g/ton-mile)58

Subcategory

Phase 2 MY
2027+

Class 7 Low-Roof (all cab styles)

96.2

Class 7 Mid-Roof (all cab styles)

103.4

Class 7 High-Roof (all cab styles)

100.0

Class 8 Low-Roof Day Cab

73.4

Class 8 Low-Roof Sleeper Cab

64.1

Class 8 Mid-Roof Day Cab

78.0

Class 8 Mid-Roof Sleeper Cab

69.6

Class 8 High-Roof Day Cab

75.7

Class 8 High-Roof Sleeper Cab

64.3

Heavy-Haul Tractors

48.3

The vehicle manufacturers that certified to EPA standards for MY 2022 are those listed in
Table 1-8. The manufacturer names with indicate that they have EPA certifications for BEVs.
The manufacturer names with 'A' indicate they have certifications for FCEVs.

Table 1-8 Vehicle Manufacturers Certified to EPA HDV Emission Standards in MY 202259

ARBOC Specialty Vehicles, LLC*

General Motors LLC

Rosenbauer Motors LLC

Autocar, LLC

Gillig LLC*

SEA Electric*

Battle Motors, Inc.*

Global Environment Product Inc

Seagrave Fire Apparatus LLC

Blue Bird Body Company*

Grove US LLC

Spartan Fire LLC

BYD Auto Industry Company Ltd*

Hino Motors, Ltd

Temsa Skoda Sabanci Ulasim
Araclari A.S.

Daimler Coaches North America

HME Inc

Terex Corporation

Daimler Truck North America
LLC*

Isuzu Motors Limited

The Shyft Group

Dennis Eagle Inc

Motor Coach Industries*

Tifton Motor Homes Inc

Eldorado National-California Inc*A

Navistar, Inc*

VanHool N.V.*

Envirotech Drive Systems Inc*

New Flyer of America, Inc*A

Vicinity Motor (Bus) Corp*

E-OneInc

Nikola Corporation*

Volvo Group Trucks, Technology,
Powertrain Engineering, a Division
of Mack Trucks*

FCAUS LLC

Oshkosh Corporation

XOS, Inc*

Ferrara Fire Apparatus Inc

PACCAR Inc*

Zeus Electric Chassis, Inc*

Ford Motor Co

Proterra Operating Company, Inc*

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The CO2 engine standards are divided by the type of vehicle where the engine will be
installed—tractor or vocational vehicles—and then further divided by engine category. The
engine standards for engines used in tractors and vocational vehicles are found in 40 CFR
1036.108 and the MY 2027 standards are shown in Table 1-9 and Table 1-10. The standards for
engines installed in tractors decrease 3.4% between MY 2021 and MY 2027. The standards for
engines installed in vocational vehicles decrease between 1.8-2% from MY 2021 to MY 2027.

Table 1-9 MY 2027 Engine CO2 Emission Standards for Engines Installed in Tractors (SET cycle)

Engine Category

CO2 Emissions
Standard (g/bhp-hr)

Medium HD

457

Heavy HD

432

Table 1-10 MY 2027 Engine CO2 Emission Standards for Heavy-Duty Engines Installed in Vocational

Vehicles (FTP cycle)

Engine Category

CO2 Emissions
(g/bhp-hr)

Light HD

552

Medium HD

535

Heavy HD

503

HD Spark Ignition

627

The engine manufacturers that currently certify to EPA standards are listed in Table 1-11.
These certifications are for compression ignition and spark ignition engines.

Table 1-11 Engine Manufacturers Certified to EPA HDE Emission Standards in MY 202259

AGA Systems, LLC

FPT Industrial S.p.A

PACCAR Inc

Agility Powertrain Systems LLC

General Motors, LLC

PARNELL USA, Inc

Bi-Phase technologies, LLC

Greenkraft, Inc

Power Solutions International, Inc

Blossman Services, Inc

Hino Motors, Ltd

Powertrain Integration LLC

Clean Fuel USA, Inc

Icom North America LLC

Roush Industries Inc

Cummins, Inc.

IMPCO Technologies, Inc

Team Quality Services, Inc

Detroit Diesel Corporation

Isuzu Motors Limited

Volvo Group Trucks, Technologies,
Powertrain Engineering, a Division
of Mack Trucks

Encore TEC LLC

Landi Renzo USA Corp

Wing Power Systems

FCAUS LLC

Navistar, Inc

Ford Motor Company

NGV Motori USA, LLC

1.3.2 Bipartisan Infrastructure Law (BIL) and Inflation Reduction Act (IRA)

1.3.2.1 BIL

The BIL60 was enacted on November 15, 2021, and contains provisions to support the
deployment of low- and zero-emission transit buses, school buses, and trucks that service ports,
as well as electric vehicle charging infrastructure and hydrogen. These provisions include
Section 71101 establishing EPA's Clean School Bus Program,61 with $5 billion to fund the
replacement of ICE school buses with clean and zero-emission buses over the next five years. In

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its first phase of funding for the Clean School Bus Program, EPA is issuing nearly $1 billion in
rebates (up to a maximum of $375,000 per bus, depending on the bus fuel type, bus size, and
school district prioritization status)"1 for replacement clean and zero-emission buses and
associated infrastructure costs.V111'62 The BIL also includes funding for DOT's Federal Transit
Administration (FTA) Low or No Emission grant program,63 with over $5.6 billion over the next
five years to support the purchase of zero- or low-emission transit buses and associated
infrastructure.64

The BIL includes up to $7.5 billion to help build out a national network of EV charging and
hydrogen fueling administered by DOT's Federal Highway Administration (FHWA) with
support from the Joint Office. This includes $5 billion for the National Electric Vehicle
Infrastructure (NEVI) Formula Program (under Division J, Title VIII).65 In September 2022, the
FHWA approved the first set of plans for the NEVI program covering all 50 states, Washington,
D.C., and Puerto Rico. The approved plans provide $1.5 billion in funding for fiscal years (FY)
2022 and 2023 to expand charging on over 75,000 miles of highway.66 One of the stated goals of
this infrastructure funding is to support equitable access to charging across the country.67
Accordingly, FHWA instructed states to incorporate public engagement in their NEVI Formula
Program planning process, including reaching out to Tribes, and rural, underserved, and
disadvantaged communities among other stakeholders. While jurisdictions are not required to
build stations specifically for heavy-duty vehicles, FHWA's guidance encourages states to
consider station designs and power levels that could support heavy-duty vehicles.68 The
remaining $2.5 billion is for the Charging and Fueling Infrastructure (CFI) Discretionary Grant
Program (under Section 11401).69 In March 2023, the first funding opportunity under the CFI
Program was opened with $700 million to deploy electric vehicle charging and hydrogen,
propane, or natural gas infrastructure in communities or along corridors.70 To support these
programs, in February 2023, DOE announced $7.4 million in funding to develop seven medium-
and heavy-duty BEV charging and hydrogen corridor infrastructure plans: from Georgia to New
Jersey (along 1-95), Indiana to Ohio (along 1-80), Houston to Los Angeles (along I-10), and
around Los Angeles (1-710 Corridor), the Northeast (New Jersey to Maine), San Francisco Bay
Area, and the Greater Salt Lake City Region.71

The BIL funds other programs that could support HD vehicle electrification. For example,
there is continued funding of the Congestion Mitigation and Air Quality (CMAQ) Improvement
Program, with more than $2.5 billion authorized each year from FY 2022 through FY 2026. The
BIL (Section 11115) amended the CMAQ Improvement Program to add, among other things,
"the purchase of medium- or heavy-duty zero emission vehicles and related charging equipment"
to the list of activities eligible for funding. The BIL establishes a program under Section 11402
"Reduction of Truck Emissions at Port Facilities" that includes grants to be administered through
FHWA aimed at reducing port emissions, including through electrification. In addition, the BIL
includes funding for DOT's Maritime Administration (MARAD) Port Infrastructure
Development Program72 and DOT's Federal Highway Administration (FHWA) Carbon
Reduction Program (Section 11403).73

vn U.S. Environmental Protection Agency. "2022 Clean School Bus (CSB) Rebates Program Guide". May 2022.
Available online: https://nepis.epa.gov/Exe/ZyPDF.cgi/P1014WNH.PDF?Dockey=P1014WNH.PDF.
vm Some recipients are able to claim up to $20,000 per bus for charging infrastructure.

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The BIL also targets batteries used for BEVs and FCEVs. It funds DOE's Battery Materials
Processing and Battery Manufacturing program,74 which grants funds to promote U.S. processing
and manufacturing of batteries for automotive and electric grid use through demonstration
projects, the construction of new facilities, and the retooling, retrofitting, and expansion of
existing facilities. This includes a total of $3 billion for battery material processing and $3 billion
for battery manufacturing and recycling, with additional funding for a lithium-ion battery
recycling prize competition, research and development activities in battery recycling, state and
local programs, and the development of a collection system for used batteries. In addition, the
BIL includes $200 million for the Electric Drive Vehicle Battery Recycling and Second-Life
Application Program for research, development, and demonstration of battery recycling and
second-life applications.

Hydrogen provisions of the BIL include funding for several programs to accelerate progress
towards the Hydrogen Shot goal, launched on June 7, 2021, to reduce the cost of clean
hydrogenlx production by 80% to $1 for 1 kg in 1 decade75 and jumpstart the hydrogen market in
the United States. This includes $8 billion for the Department of Energy's Regional Clean
Hydrogen Hubs Program to establish networks of clean hydrogen producers, potential
consumers, and connective infrastructure in close proximity. The BIL provisions establishing
this program include several diversity requirements. For example, the program must fund at least
one hub each that produces hydrogen using fossil fuels, renewable energy, and nuclear power;
and a minimum of two hubs must be sited in natural gas-producing regions.76 Additional BIL
provisions include $1 billion for a Clean Hydrogen Electrolysis Program and $500 million for
Clean Hydrogen Manufacturing and Recycling Initiatives.77 The BIL also called for development
of a Clean Hydrogen Production Standard to guide DOE hub and Research, Development,
Deployment, and Diffusion (RDD&D) actions; and a National Clean Hydrogen Strategy and
Roadmap to facilitate widescale production, processing, delivery, storage, and use of clean
hydrogen. These BIL programs are currently under development and further details are expected
over the course of C Y 2023.

1.3.2.2 IRA Sections 13502 and 13403

The IRA,78 which was enacted on August 16, 2022, contains several provisions relevant to
vehicle electrification and the associated infrastructure via tax credits, grants, rebates, and loans
through CY 2032, including two key provisions that provide a tax credit to reduce the cost of
producing qualified batteries (battery tax credit) and to reduce the cost of purchasing qualified
ZEVs (vehicle tax credit). The battery tax credit in "Advanced Manufacturing Production
Credit" in IRA section 13502 and the "Qualified Commercial Clean Vehicles" vehicle tax credit
in IRA section 13403 are included quantitatively in our analysis.

IRA section 13502, "Advanced Manufacturing Production Credit," provides tax credits for the
production and sale of battery cells and modules of up to $45 per kilowatt-hour (kWh), and for
10 percent of the cost of producing applicable critical minerals (including those found in
batteries and fuel cells, provided that the minerals meet certain specifications), when such
components or minerals are produced in the United States. These credits begin in CY 2023 and

K The BIL defines "clean hydrogen" as hydrogen produced in compliance with the GHG emissions standard
established under 42 U.S. Code section 16166(a), including production from any energy source, where the standard
developed shall define the term to mean hydrogen produced with a carbon intensity equal to or less than 2 kilograms
of carbon dioxide-equivalent produced at the site of production per kilogram of hydrogen produced.

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phase down starting in CY 2030, ending after CY 2032. With projected direct manufacturing
costs for heavy-duty vehicle batteries on the order of $65 to $275/kWh in the 2025-2030
timeframe,79 this tax credit has the potential to noticeably reduce the cost of qualifying batteries
and by extension, the cost of BEVs and FCEVs with qualifying batteries. We did not include a
detailed cost breakdown of fuel cells quantitatively in our analysis, but the potential impact on
fuel cells may also be significant because platinum (an applicable critical mineral commonly
used in fuel cells) is a major contributor to the cost of fuel cells.80

We limited our assessment of this IRA section 13502 tax credit provision in our Chapter 2
analysis to the tax credits for battery cells and modules. Pursuant to the IRA, qualifying battery
cells must have an energy density of not less than 100 watt-hours per liter, and we expect that
batteries for heavy-duty BEVs and FCEVs will exceed this requirement as described in DRIA
Chapter 2.4.2.2. Qualifying battery cells must be capable of storing at least 12 watt-hours of
energy and qualifying battery modules must have an aggregate capacity of not less than 7 kWh
(or, for FCEVs, not less than 1 kWh); typical battery cells and modules for motor vehicles also
exceed these requirements.81 Additionally, the ratio of the capacity of qualifying cells and
modules to their maximum discharge amount shall not exceed 100:1. We expect that battery cells
and modules in heavy-duty BEVs and FCEVs will also meet this requirement because the high
costs and weight of the batteries and the competitiveness of the heavy-duty industry will pressure
manufacturers to allow as much of their batteries to be useable as possible. We did not consider
the tax credits for critical minerals quantitatively in our analysis. However, we note that any
applicability of the critical mineral tax credit may further reduce the costs of batteries.

We included this battery tax credit by reducing the direct manufacturing costs of batteries in
BEVs and FCEVs, but not the associated indirect costs. At present, there are few manufacturing
plants for HD vehicle batteries in the United States, which means that few batteries would
qualify for the tax credit now. We expect that the industry will respond to this tax credit
incentive by building more domestic battery manufacturing capacity in the coming years, but this
will take several years to come to fruition. Thus, we have chosen to model this tax credit by
assuming that HD BEV and FCEV manufacturers fully utilize the module tax credit (which
provides $10 per kWh) and gradually increase their utilization of the cell tax credit (which
provides $35 per kWh) for MY 2027-2029 until MY 2030 and beyond, when they earn 100
percent of the available cell and module tax credits. Further discussion of this battery tax credit
and our battery costs can be found in DRIA Chapter 2.4.3.1.

IRA section 13403, "Qualified Commercial Clean Vehicles," creates a tax credit of up to
$40,000 per Class 4 through 8 HD vehicle (up to $7,500 per Class 2b or 3 vehicle) for the
purchase or lease of a qualified commercial clean vehicle. This tax credit is available from CY
2023 through CY 2032 and is based on the lesser of the incremental cost of the clean vehicle
over a comparable ICE vehicle or the specified percentage of the basis of the clean vehicle, up to
the maximum applicable limitation. By effectively reducing the price a vehicle owner must pay
for a HD ZEV and the incremental difference in cost between it and a comparable ICE vehicle—
by $40,000 in many cases—more vehicle purchasers will be poised to take advantage of the cost
savings anticipated from total cost of ownership, including operational cost savings from fuel
and maintenance and repair compared with ICE vehicles. Among other specifications, these
vehicles must be on-road vehicles (or mobile machinery) that are propelled to a significant extent
by a battery-powered electric motor or are qualified fuel cell motor vehicles (also known as fuel
cell electric vehicles, FCEVs). For the former, the battery must have a capacity of at least 15

-------
kWh (or 7 kWh if it has a gross vehicle weight rating of less than 14,000 pounds (Class 3 or
below)) and must be rechargeable from an external source of electricity. This limits the qualified
vehicles to BEVs and plug-in hybrid electric vehicles (PHEVs), in addition to FCEVs. Since this
tax credit overlaps with the model years for which we are proposing standards (MYs 2027
through 2032), we included it in our calculations for each of those years in our feasibility
analysis for our proposed standards (see Chapter 2).

For BEVs and FCEVs, the per-vehicle tax credit is equal to the lesser of the following, up to
the cap limitation: (A) 30 percent of the BEV or FCEV cost, or (B) the incremental cost of the
BEV or FCEV when compared to a comparable (in size and use) ICE vehicle. The limitation on
this tax credit is $40,000 for vehicles with a gross vehicle weight rating of equal to or greater
than 14,000 pounds (Class 4-8 commercial vehicles) and $7,500 for vehicles with a gross
vehicle weight rating of less than 14,000 pounds (commercial vehicles Class 3 and below). For
example, if a BEV with a gross vehicle weight rating of equal to or greater than 14,000 pounds
costs $350,000 and a comparable ICE vehicle costs $150,000,79 the tax credit would be the
lesser of the following, subject to the limitation: (A) 30 percent x $350,000 = $105,000 or (B)
$350,000 - $150,000 = $200,000. (A) is less than (B), but (A) exceeds the limit of $40,000, so
the tax credit would be $40,000. For PHEVs, the per-vehicle tax credit follows the same
calculation and cap limitation as for BEVs and FCEVs except that (A) is 15 percent of the PHEV
cost.

For details on how we estimated the impact of the tax credit in our feasibility analysis for
BEVs and FCEVs, see Chapters 2.4.3.5 (BEVs) and 2.5.2.3 (FCEVs). We did not analyze
PHEVs because they are not part of our technology packages in this proposal. The tax credit
amounts for each vehicle type included in our analysis in MYs 2027 and 2032 are shown in
DRIA Chapter 2.8.2.

We project that the impact of the IRA vehicle tax credit will be significant, as shown in DRIA
Chapter 2.8.2. In many cases, the incremental cost (with the tax credit) of a BEV compared to an
ICE vehicle is eliminated, leaving only the cost of the electric vehicle supply equipment (EVSE)
as an added upfront cost to the BEV owner. Similarly, in some cases, the tax credit eliminates the
upfront cost of a FCEV compared to an ICE vehicle.

1.3.2.3 Other IRA Provisions

There are many other provisions of the IRA that we expect will support application of BEV
and FCEV technologies in the heavy-duty fleet. Due to the complexity of analyzing the
combined potential impact of these provisions, we did not quantify their potential impact in our
assessment of costs and feasibility, but we note that they are expected to help to reduce many
obstacles to application of BEV and FCEV technologies in HD vehicles and may further support
ZEV adoption rates at the levels we currently project in the technology packages for the
proposed program.

Section 13404, "Alternative Fuel Refueling Property Credit," modifies an existing tax credit
that applies to alternative fuel refueling property (e.g., electric vehicle charging equipment and
hydrogen fueling stations) and extends the tax credit through CY 2032. The credit also applies to
refueling property that stores or dispenses specified clean-burning fuels, including at least 85
percent hydrogen, into the fuel tank of a motor vehicle. Starting in CY 2023, this provision
provides a tax credit of up to 30 percent of the cost of the qualified alternative fuel refueling

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property (e.g., HD BEV charging equipment), up to $100,000 per item when located in low-
income or non-urban area census tracts and certain other requirements are met. We expect that
many HD BEV owners will need charging equipment installed in their depots for overnight or
other off-shift charging, and this tax credit will effectively reduce the costs of installing charging
infrastructure and, in turn, further effectively reduce the total costs associated with owning a
BEV for many HD vehicle owners. Additionally, this tax credit will offset some of the costs of
installing high-powered public and private charging equipment that may be necessary to charge
HD BEVs with minimal downtime during the day. Similarly, we expect that this tax credit will
reduce the costs associated with refueling heavy-duty FCEVs, whose owners may rely on public
hydrogen refueling stations or those installed in their depots. We expect this tax credit will help
incentivize the build out of the charging and hydrogen refueling infrastructure necessary for high
BEV and FCEV adoption, which will further support increased BEV and FCEV uptake.

Section 60101, "Clean Heavy-duty Vehicles," amends the CAA to add new section 132 (42
U.S.C. 7432) and appropriates $1 billion to the Administrator, including $600 million generally
for carrying out CAA section 132 and $400 million to make awards under CAA section 132 to
eligible recipients/contractors that propose to replace eligible vehicles to serve one or more
communities located in an air quality area designated pursuant to CAA section 107 as
nonattainment for any air pollutant, in FY 2022 and available through FY 2031. CAA section
132 requires the Administrator to implement a program to make awards of grants and rebates to
eligible recipients (defined as States, municipalities, Indian tribes, and nonprofit school
transportation associations), and to make awards of contracts to eligible contractors for providing
rebates, for up to 100 percent of costs for: 1) the incremental costs of replacing a Class 6 or Class
7 heavy-duty vehicle that is not a zero-emission vehicle with a zero-emission vehicle (as
determined by the Administrator based on the market value of the vehicles); 2) purchasing,
installing, operating, and maintaining infrastructure needed to charge, fuel, or maintain zero-
emission vehicles; 3) workforce development and training to support the maintenance, charging,
fueling, and operation of zero-emission vehicles; and 4) planning and technical activities to
support the adoption and deployment of zero-emission vehicles.

Section 60102, "Grants to Reduce Air Pollution at Ports," amends the CAA to add a new
section 133 (42 U.S.C. 7433) and appropriates $3 billion, $750 million of which is for projects
located in areas of nonattainment for any air pollutant, in FY 2022 and available through FY
2027, to reduce air pollution at ports. Competitive rebates or grants are to be awarded for the
purchase or installation of zero-emission port equipment or technology for use at, or to directly
serve, one or more ports; to conduct any relevant planning or permitting in connection with the
purchase or permitting of zero-emission port equipment or technology; and to develop qualified
climate action plans. The zero-emission equipment or technology either 1) produces zero
emissions of GHGs, listed criteria pollutants, and hazardous air pollutants or 2) it captures 100%
of the emissions produced by an ocean-going vessel at berth.

Section 60103, "Greenhouse Gas Reduction Fund," amends the CAA to add a new section
134 (42 U.S.C. 7434) and appropriates $27 billion, $15 billion of which is for low-income and
disadvantaged communities, in FY 2022 and available through FY 2024, for a greenhouse gas
reduction grant program. The program supports direct investments in qualified projects at the
national, regional, State, and local levels, and indirect investments to establish new or support
existing public, quasi-public, not-for-profit, or nonprofit entities that provide financial assistance
to qualified projects. The program focuses on the rapid deployment of low- and zero-emission

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products, technologies, and services to reduce or avoid GHG emissions and other forms of air
pollution.

Section 60104, "Diesel Emissions Reductions," appropriates $60 million (2 percent of which
must be reserved for administrative costs necessary to carry out the section's provisions), in FY
2022 and available through FY 2031, for grants, rebates, and loans under section 792 of the
Energy Policy Act of 2005 (42 U.S.C. 16132) to identify and reduce diesel emissions resulting
from goods movement facilities and vehicles servicing goods movement facilities in low-income
and disadvantaged communities to address the health impacts of such emissions on such
communities.

Section 70002 appropriates $3 billion in FY 2022 and available through FY 2031 for the
United States Postal Service to purchase ZEVs ($1.29 billion) and to purchase, design, and
install infrastructure to support zero-emission delivery vehicles at facilities that the United States
Postal Service owns or leases from non-Federal entities ($1.71 billion).

Section 13501, "Extension of the Advanced Energy Project Credit," allocates $10 billion in
tax credits for facilities to domestically manufacture advanced energy technologies, subject to
certain application and other requirements and limitations. Qualifying properties now include
light-, medium-, or heavy-duty electric or fuel cell vehicles along with the technologies,
components, or materials for such vehicles and the associated charging or refueling
infrastructure. They also include hybrid vehicles with a gross vehicle weight rating of not less
than 14,000 pounds along with the technologies, components, or materials for them.

Sections 50142, 50143, 50144, 50145, 50151, 50152, and 50153 collectively appropriate
nearly $13 billion to support low- and zero-emission vehicle manufacturing and energy
infrastructure. These provisions are intended to help accelerate the ability for industry to meet
the demands spurred by the previously mentioned IRA sections, both for manufacturing vehicles,
including BEVs and FCEVs, and for energy infrastructure.

Section 13204, "Clean Hydrogen," amends section 45V of the Internal Revenue Code (i.e.,
Title 26) to offer a tax credit to produce hydrogen for qualified clean production facilities that
use a process that results in a lifecycle GHG emissions rate of not greater than 4 kg of C02e per
kg of hydrogen. This hydrogen production tax credit is eligible for qualified clean hydrogen
production facilities whose construction begins before January 1, 2033, and is available during
the 10-year period beginning on the date such facility was originally placed in service. The credit
increases to a maximum of $3 per kilogram produced as the lifecycle GHG emissions rate is
reduced to less than 0.45 kg of C02e per kg of hydrogen. Facilities that received credit for the
construction of carbon capture and direct air capture equipment or facilities (i.e., under 45Q) do
not qualify, and prevailing wage and apprenticeship requirements apply. Section 60113,
"Methane Emissions Reduction Program," amends the CAA by adding Section 136 and
appropriates $850 million to EPA to support methane mitigation and monitoring, plus authorizes
a new fee of $900 per ton on "waste" methane emissions that escalates after two years to $1,500
per ton. These combined incentives promote the production of hydrogen in a manner that
minimizes its potential greenhouse gas impact.

While there are challenges facing greater adoption of heavy-duty ZEV technologies, the IRA
provides many financial incentives to overcome these challenges and thus would also support
our proposed rulemaking. We expect IRA sections 13502 and 13403 to support the adoption of

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HD ZEV technologies in the market, as detailed in our assessment of the appropriate GHG
standards we are proposing. Additionally, we expect IRA sections 13404, 60101-60104, 70002,
13501, 50142-50145, 50151-50153, and 13204 to further accelerate ZEV adoption, but we are
not including them quantitatively in our analyses.

1.3.3 California Advanced Clean Trucks Regulation

The California Air Resources Board (CARB) adopted the Advanced Clean Trucks (ACT)
Regulation on March 15, 2021.82 EPA granted the ACT rule waiver requested by California
under CAA section 209(b) on March 30, 2023.

The ACT Regulation requires manufacturers who certify Class 2b through 8 chassis or
complete vehicles with combustion engines to sell zero-emission trucks as an increasing
percentage of their annual state sales from MY 2024 to MY 2035. The ACT Regulation is
applicable for all vehicles sold in California with gross vehicle weight rating greater than 8,500
pounds. In addition, five states adopted the California ACT Regulation in late 2021 including
Massachusetts83, New York84, New Jersey85, Oregon86, and Washington87.

The ACT Regulation requires a specified percentage of heavy-duty ZEVs each model year
with increasing percentages for each subsequent model year, as reflected in Table 1-12. The
percentages are categorized by Class 2b-3 vehicles, Class 4-8 vocational vehicles, and Class 7-8
tractors. Major program milestones include MYs 2030 and 2035, which require 30 percent and
55 percent of Class 2b-3 vehicles, 50 percent and 75 percent of Class 4-8 vocational vehicles,
and 30 percent and 40 percent of Class 7-8 tractors that are produced to be ZEVs for those
model years, respectively.

Table 1-12 California Air Resource Board ACT Regulation ZEV Sales Percentage Schedule

Model Year

Class 2b-3
Group

Class 4-8
Group

Class 7-8
Tractors
Group

2024

2025

11%

2026

10%

13%

10%

2027

15%

20%

15%

2028

20%

30%

20%

2029

25%

40%

25%

2030

30%

50%

30%

2031

35%

55%

35%

2032

40%

60%

40%

2033

45%

65%

40%

2034

50%

70%

40%

2035 and beyond

55%

75%

40%

ACT includes a credit program that allows credits generated for each ZEV and near zero-
emission vehicle (NZEV) to offset deficits generated from the production and sale in California
of vehicles and tractors. Credits may be banked, traded, sold and otherwise transferred between
manufacturers. Table 1-13 describes the multipliers for credits and deficits by vehicle class.
Credits for NZEVs may only be generated through MY 2035. The generated credits have a set
time frame for expiration based on the model year in which the credits were generated. Credits

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generated by certifying ZEVs between MY 2021 through MY 2023 expire in MY 2030 and
credits accumulated during MY 2024 and later model years expire after five model years.

Table 1-13 CARB Weight Class Modifiers

Vehicles in
the Class
2b-3

Class 4-5

Class 6-7

Class 8

Vehicles in
the Class 7
and 8
Tractor
Group

Vehicles in the

Vehicles in

Class 4-8

the Class 4-8

Group

Weight
Class

0.8

1.5

2.5

Modifier

The ACT Regulation also has a provision for hybrid vehicles being sold in MYs 2030 and
beyond, which requires that a hybrid have an all-electric 75-mile range.82

1.4 GHG-Reducing Technologies for ICE-Powered Vehicles

1.4.1 HP Engine Technologies

This section considers technologies applicable to ICE engines to reduce GHG emissions. The
emission reductions achieved through ICE and hybrid technologies may be used towards meeting
the overall average CO2 emission levels proposed in this rulemaking. Improvements for CO2
emission reductions are achievable through adoption of current offerings in the marketplace as
well as additional advancements.

1.4.1.1 Hybrid Powertrains

The industry is currently developing many variations of hybrid powertrain systems, and the
fully integrated HD hybrids developed to date have claimed fuel consumption and CO2
emissions reductions ranging from 10 to 30 percent in real world use, shown in Table 1-14,
compared to traditional ICE vehicles.

Table 1-14 Hybrid Heavy-Duty Vehicle Examples

Manufacturer

HDV Operation

Benefit Compared to Traditional HDV
Real World Use

Marketed in 2023

New Flyer

Transit Bus

10-29% depending on route88

NovaBus

Transit Bus

Up to 30%89 at speeds of 9-18 mph

Allison transmission/
Odyne hybrid systems90

Plug-in/engine elec production for PTO
based hybrid system, launch assist and
hill climbing for utility bucket trucks,
digger derricks, cranes and other
applications requiring all day stationary
power at worksites

NREL report shows reduction of 75%
CO2 in idle emissions of PTO use91, idle
use is 30%+ of vehicle operation and uses
10% of the fuel92.

Pierce Manufacturing

Fire Truck

Real world use showed 1500 gallons of
diesel saved in one month.93

Under Development as of 2023

Hyliion

Class 8 Tractor (Diesel/CNG)

Article states performing certification
protocols in 2023 and then production.
Also, plans to adopt GE engine for lower
CO2 a few years later 94

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Hybrid powertrains consist of an ICE as well as an electric drivetrain and some designs also
incorporate plug-in capability. The ICE uses a consumable fuel (like diesel) to produce power
which can either propel the vehicle directly or charge the traction battery from which the electric
drivetrain draws its energy. These two sources of power can be used in combination to do work
and move the vehicle, or they may operate individually, switching between the two sources.
Hybrid technology is well established in the U.S. light-duty market, where some manufacturers
have been producing light-duty hybrid models for several decades and others are looking to
develop hybrid models in the future. Hybrid powertrains are available today in a number of
heavy-duty vocational vehicles including passenger van/shuttle bus, transit bus, street sweeper,
refuse hauler, and delivery truck applications. Heavy-duty hybrid vehicles may include a power
takeoff (PTO) system that is used to operate auxiliary equipment, such as the boom/bucket on a
utility truck or the water pump on a fire truck.

Hybrid powered vehicles can provide CO2 emission reductions from splitting or blending of
ICE and electric operation. One of the main barriers to hybrid technology in heavy-duty
applications has been the cost associated with having two powertrains installed in the same
vehicle: one for the ICE and another for the electric driveline. The hybrid transit buses have been
purchased for use in cities including Philadelphia, PA and Toronto Canada. Utility trucks with
ePTOs in which the electricity can be provided by plug-in/hybrid engine have also been
purchased.

Hybrid vehicles reduce CO2 emissions through four primary mechanisms:

• The ICE in the series hybrid powertrain (engine operates as a generator to create electricity
for the battery) can be optimized (through downsizing, modifying the operating cycle, or
other control techniques) to operate at or near its most efficient engine speed-load conditions
more often than is possible with a conventional engine-transmission driveline and the power
loss due to engine downsizing can be mitigated by employing power assist from the
secondary, electric driveline.

• Hybrid vehicles typically include regenerative braking systems that capture some of the
energy normally lost while braking and store it in the traction battery for later use. Use is
typically used to provide additional torque upon initial acceleration from stop or additional
power for moving the vehicle up a steep incline.

• The engine is turned off when it is not needed, such as when the vehicle is coasting or when
the vehicle is stopped. Furthermore, vehicle systems can be electrified if a 48V or higher
battery system is incorporated into the vehicle. Systems for electrification include the cabin
comfort and power steering, etc. The electrical systems are more efficient than their
conventional counterparts which utilize an accessory drive belt on a running engine. When
the engine is stopped these accessory loads are supported by the traction battery.

• Plug-in hybrid vehicles can further reduce CO2 emissions by increasing the battery storage
capacity and adding the ability to connect to the electrical power grid to fully charge the
battery when the vehicle is not in service, which can significantly expand the amount of all-
electric operation.

Hybrid vehicles can utilize a combination of some or all of these mechanisms to reduce fuel
consumption and CO2 emissions. The magnitude of the CO2 reduction achieved depends on the

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utilization/optimization of the above mechanisms and the powertrain design decisions made by
the manufacturer.

One area where hybrid system design decisions are impactful is in the choice of engine size
and its effect on balancing GHG emissions and performance. Some manufacturers may forgo
downsizing the engine when incorporating hybrid technologies. In these cases, while vehicle
performance is vastly improved, the GHG emissions improvements are less significant than if the
engine were downsized to maintain the same overall performance (from combining ICE and
electric power and torque) as the non-hybrid powertrain version. This "non-downsizing"
approach is used for vehicles where high load towing and/or hauling are an integral part of their
performance requirements. In these cases, if the engine were to be downsized, the battery would
be quickly drained during a long hill climb or heavy load operation, leaving only the downsized
engine to carry the entire load. Because hauling capability is an important attribute for many HD
vehicle applications, manufacturers may be hesitant to offer a truck with a downsized engine that
reduces towing/hauling performance when the battery state-of-charge is low, and therefore,
engines are traditionally not downsized for HD hybrid vehicles for these applications.

Strong hybrid technology refers to a design where an axial electric motor is connected to the
transmission input shaft and coupled to the engine crankshaft through a clutch. The axial motor
is a motor/generator that can provide sufficient torque for launch assist as well as all-electric
operation, but also provides the ability to recover significant amounts of braking energy.

A hybrid drive unit is a complex design that consists of discrete components such as an
electric traction motor/generator, transmission, DC-to-DC inverter, power controller, and cooling
devices. These components are then utilized in a hybrid powertrain that is classified as either
"series" or "parallel."

With parallel hybrid designs, the vehicle can be powered in one of three ways: directly by the
engine, directly by the electrical motor, or by both systems working together. In parallel hybrids,
the electric driveline and the combustion engine work together to propel the vehicle, where
torque produced by the electric motor and engine crankshaft are blended and combined through
couplings, planetary gear sets, or clutches. The choice of using a series or parallel design is
dependent on a vehicle's specific application and performance requirements. Several types of
motors and generators have been developed for both parallel and series hybrid-electric drive
systems, many of which merit further evaluation and development for specific heavy-duty
applications and use cases, where the opportunity for reduced CO2 emissions can be fully
realized.

In a series hybrid, the gasoline- or diesel-fueled engine simply generates electrical energy that
is either used directly by the electric motor or stored in the battery for future use by the electric
motor, but it never directly provides power to the wheels. Series HEVs typically have larger
electric motors with higher power ratings because the motor alone must propel the vehicle. This
design may be applicable to a variety of HD vehicle applications.

With advances in hybrid technology, some vehicles utilize both series and parallel powertrain
design elements (known as "series-parallel" hybrids) where the operation of the two hybrid drive
units is controlled by an on-board computer that chooses the most efficient way to operate the
vehicle during a given set of speed-load conditions.

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An electrical energy storage system is needed to store energy generated by the engine capture
energy recovered during vehicle braking events, also called regenerative braking, and supply
energy to the electric motor when the driver demands power. This technology has seen a
tremendous amount of improvement over the last decade both in terms of cost and capability.
Advanced battery technologies are emerging that provide the hybrid vehicle its needed
performance and efficiency gains while still providing long product life. The focus on energy
storage technologies such as nickel metal-hydride (NiMH) and lithium-ion batteries, along with
ultra-capacitors for the heavy-duty applications, are expected to yield further performance
improvements as well as lower CO2 emissions. The progress of hybrid vehicle battery
technology in the heavy-duty sector is expected to be supported by continued research and
development for high sales volume hybrid applications in the light-duty sector.

Since heavy-duty hybrid vehicles use regenerative braking to recover kinetic energy that is
normally converted to heat by the braking system, they also experience less brake wear. A non-
hybrid ICE vehicle relies on friction brakes at the wheels, sometimes combined with an optional
engine retarder or driveline retarder, to provide stopping power and reduce vehicle speed. During
normal braking, the non-hybrid ICE vehicle's kinetic energy is wasted as it is converted to heat
by the friction. This brake configuration requires heavy and consumable components which can
require frequent maintenance and replacement. Since hybrid electric systems recover some of the
vehicle's kinetic energy through regenerative braking, this previously wasted energy is captured
by the hybrid driveline's motor/generator and directed to the vehicle's energy storage system,
with any remaining kinetic energy being dissipated through wheel brakes or by a driveline or
transmission retarder. Regenerative braking in a hybrid electric vehicle requires integration with
the vehicle's foundation (friction) braking system to maximize performance and safety.

Despite the CO2 reducing potential for hybrids as discussed above, there is no single design
solution applicable for all HD vehicle weight classes because each of them is built to satisfy
specific customer requirements and use cases, as shown in the examples in Table 1-14. A limited
set of hybrid design choices for a given vehicle must be made relative to this range of customer
performance requirements and priorities. Challenges in designing a hybrid vehicle's electric
motor subsystems (such as the sizing of power electronics and cooling system capacity) must be
considered when specifying the power, power density, and cost of the motor assemblies. High-
speed electric motors can significantly reduce weight and size of the motor, but they require
speed reduction gear sets, which can offset some of the weight savings, reduce reliability, and
add cost and complexity. While air-cooled motors are simpler and generally less expensive than
liquid-cooled motors, they are also larger and heavier and they require a supply of ambient
cooling air, which can carry dirt, water, and other contaminants to the motor. Liquid-cooled
motors are generally smaller and lighter for a given power rating, but they may require more
complex cooling systems that can be avoided with air-cooled designs. Heavy-duty specific
design and development of the hybrid-electric motors, power electronics, regenerative braking
system, and control optimization strategies will be needed to fully realize GHG-reducing
potential of this technology.

1.4.1.2 Hydrogen-Fueled Internal Combustion Engines

Currently, hydrogen fueled internal combustion engines (H2-ICE) are in the prototype stage.
H2-ICE is a technology to provide zero tailpipe emissions for hydrocarbons, carbon monoxide
and carbon dioxide. H2-ICE exhaust aftertreatment systems would not include diesel oxidation

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catalyst (DOC) or diesel particulate filter (DPF) components. However, NOx emissions are still
formed during the H2-ICE combustion process and therefore a selective catalytic reduction
(SCR) system would still be required, though it may be smaller in size than that used in a
comparable diesel-fueled ICE. The use of lean air-fuel ratios, and not exhaust gas recirculation
(EGR), is the most effective way to control NOx in a H2-ICE, as EGR is less effective with H2
due to the absence of CO2 in the exhaust gas.

H2-ICE technology can be implemented rapidly, using an OEM's existing tooling,
manufacturing processes, and engine design expertise. In concept, H2-ICE engines are very
similar to existing ICEs and can leverage the extensive technical expertise manufacturers have
developed with existing products. Similarly, H2-ICE products can be built on the same assembly
lines as traditional ICE vehicles, by the same workers and with many of the same component
suppliers.

H2-ICE incorporate several differences from their diesel baseline. Components such as the
cylinder head, valves, seals, piston, and piston rings would be unique to the H2-ICE to control
H2 leakage during engine operation. Another significant difference between a diesel-fueled ICE
and a H2-ICE is the fuel storage tanks. The hydrogen storage tanks are substantially more
expensive than today's diesel fuel tanks. The fuel tanks likely to be used by H2-ICE are
identical to those used by a fuel cell electric vehicle (FCEV) and they may utilize either
compressed storage (350 or 700 Bar pressure) or cryogenic storage (temperatures as low as -253
Celsius). Please refer to Chapter 1.7.2 of this document for the discussion regarding H2 fuel
storage tanks.

H2-ICE could hasten the development of hydrogen infrastructure and remove the barrier of
ultra-pure (no contaminants) hydrogen needed for FCEVs. Hydrogen infrastructure exists in
limited quantities in some parts of the country for applications such as forklifts, buses, and LDVs
and HDVs at ports. Federal funds are being used to support the development of additional hubs
and other hydrogen related infrastructure items through the BIL and IRA, as described in more
detail in Chapter 1.8.95

1.4.2 Aerodynamics

Aerodynamic improvement benefits are best realized in HD vehicles that travel at highway
speeds. The CO2 emission reduction benefits of improved aerodynamics increase as vehicle
speed increases. The Regulatory Impact Analyses for the Greenhouse Gas Emissions and Fuel
Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles - Phase 296 contains an
extensive description of aerodynamic improvements for Class 8 tractors. Aerodynamic
improvements on Class 8 sleeper cab were noted in SuperTruck 2 updates from Daimler (10%
(tested tractor))97, Volvo (15% (some was due to trailer))98, and PACCAR (—30% (63% split
with tractor/trailer) )." CO2 emission reductions are typically about half that of the aerodynamic
improvement. By reducing the energy required to move a truck down the road, aerodynamic
improvements can extend the range of BEV/FCEV/hybrid for a given battery size.

1.5 Battery Electric Vehicle Technologies

The application of battery electric vehicle technologies primarily results in the effective
replacement of the ICE powertrain with a battery electric propulsion system. The battery electric

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propulsion system includes a battery pack that provides the power to the motor to move the
vehicle.

Battery technology improvements are being widely researched in industry and academia with
goals to lengthen vehicle range and increase battery life. Battery technologies that would result
in a significant jump in battery performance include semi-solid state and solid-state.
Improvements in charging strategies can also increase a battery's operational life and have been
demonstrated in transit bus applications.

1.5.1 Batteries

The batteries used for today's BEVs are very advanced; however, the fundamental theory of
the battery continues to include two half-cell electrodes separated by a membrane separator that
is submerged in a conductive electrolyte. These half-cells, together, make up a battery cell.
During charge and discharge cycles, a chemical reaction takes place at each of the electrodes
when ions, such as lithium, move through a conductive medium between the electrodes. Here, an
electron is either released or consumed, in turn generating an electric current. This electricity is
used to perform work by converting the electric current into mechanical work using an electric
motor. While some heat is generated during the chemical process, all reactions are contained
within the cell and no emissions are produced from the battery cell.

1.5.1.1 Battery Design Parameters

Battery design involves balancing considerations of costx and parameters related to
performance including specific energyxl and power, energy densityxu, temperature impact on
performance, durability, and safety. These parameters typically vary based on the battery
chemistry of the cathode and anode materials, and the conductive electrolyte medium at the cell
level. Different battery chemistries have different intrinsic values. External factors such as
ambient temperature can also affect the performance of the battery. There are extensive bodies of
work within each of these areas that are beyond the scope of this document. Nonetheless,
because of the novel nature of these technologies for HD application, we provide a brief
overview of the different energy and power capacities of batteries depending on their battery
chemistries.

Design choices about the different energy and power capacities to emphasize in a battery can
depend on its battery chemistry. Common battery chemistries today include nickel-manganese-
cobalt (NMC), nickel-cobalt-aluminum (NCA), and iron-phosphate (LFP) based-chemistries.
Nickel-based chemistries typically have higher gravimetricxl and volumetric energy densities™
than iron phosphate-based chemistries. Batteries have a nested design: a group of cells are placed
inside a module and a group of modules are placed inside a pack. While the modules and packs
provide design simplicity and structure support, energy or power is only housed at the chemistry

x Cost, here, is associated with cost of the battery design produced at scale instead of decrease in cost of batteries
from high volume production. This cost may be associated with using more expensive minerals (nickel and cobalt
instead of iron phosphate). Alternatively, some battery cell components may be more expensive for the same
chemistry. For example, power battery cells are more expensive to manufacture than energy battery cells because
these cells require thinner electrodes which are more complex to produce.

X1 Battery specific energy (also referred to as gravimetric energy density) is a measure of battery energy per unit of
mass.

xn Battery energy density (also referred to as volumetric energy density) is a measure of battery energy per unit of
volume.

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level. Therefore, any additional mass such as the cell, module, and pack casings will only add to
the weight of the battery without increasing the energy of the overall system. In recent years,
some pack producers have eliminated the module in favor of a "cell-to-pack" design in recent
years.XU1 Here, the module is eliminated where cells are placed directly into battery packs without
the intermediate module component; the purpose of this to reduce both weight and volume to the
battery pack and thus increase the specific energy and energy density, respectively.

Specific energy and power and energy density are a function of how much energy or power
can be stored per unit mass or volume; these values typically have units of Watt-hour per
kilogram (Wh/kg), watt per kilogram (W/kg) or Watt-hour per liter (Wh/L), respectively.
Therefore, for a given battery weight, the energy (in kilowatt-hour or kWh) can be calculated. A
battery chemistry with high specific energy and a lower weight may yield the same amount of
energy as a battery chemistry with a lower specific energy and higher weight. An example of
this can be found in Table 1-15.

Table 1-15 Battery weight and volume to meet vehicle requirement for two different chemistries

Battery
Chemistry

Vehicle Energy
Requirement
(kWh)

Specific Energy
(Wh/kg)

Weight of
Battery (kg)

Energy
Density
(Wh/L)

Volume of
Battery (L)

100

200

500

400

250

100

1,000

200

500

External factors, especially temperature, can have a strong influence on the performance of
the battery; for example, lower temperatures typically result in lower useable energy. For more
efficient operation, batteries are maintained at a particular operating temperature range, this is
commonly referred to as conditioning of the battery. Heavy-duty BEVs today include thermal
management systems to keep the battery operating within a desired temperature range. If the
battery is plugged in overnight, the manufacturer may allow for grid energy to maintain this
temperature range. Generally, this is referred to as pre-conditioning. However, during
operation, the energy will have to come from the energy stored within the battery itself.
Therefore, additional energy for battery conditioning will be required for vehicles operating in
hot and cold climates.100 Cold temperatures, in particular, can result in reduced useable energy as
a result of reduced mobility of the lithium ions in the liquid electrolyte; for the driver, this may
mean lower range. Battery thermal management is also used during hot ambient temperatures to
keep the battery from overheating.

Another important battery design consideration is the durability of the battery. Durability is
frequently associated with cycle life, where cycle life is the number of times a battery can fully
charge and discharge before the battery is no longer used for its original purpose. In 2015 the
United Nations Economic Commission for Europe (UN ECE) began studying the need for a
Global Technical Regulation (GTR) governing battery durability in light-duty vehicles. In 2021
it finalized United Nations Global Technical Regulation No. 22, "In-Vehicle Battery Durability
for Electrified Vehicles,"101 or GTR No. 22, which provides a regulatory structure for contracting
parties to set standards for battery durability in light-duty BEVs and PHEVs. Likewise, although
not finalized, the UN ECE GTR working group began drafting language for HD BEVs and

xm BYD's "blade" cells are an example of cell-to-pack technology.

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hybrid electric vehicles. Loss of electric range could lead to a loss of utility, meaning electric
vehicles are driven less and therefore displace less distance travelled that might otherwise be
driven in conventional vehicles. Furthermore, a loss in utility could also dampen purchaser
sentiment.

For batteries that are used in HD BEVs, the state-of-health (SOH) is an important design
factor. The environmental performance of electrified vehicles may be affected by excess
degradation of the battery system over time. However, the durability of a battery is not limited
to the cycling of a battery, there are many phenomena that can impact the duration of usability of
a battery. As a battery goes through charge and discharge cycles, the SOH of the battery
decreases. Capacity fade, increase in internal resistance, and voltage loss, for example, are other
common metrics to measure the SOH of a battery. These parameters together help better
understand and define the longevity or durability of the battery. The SOH and, in turn, the cycle
life of the battery is determined by both the chemistry of the battery as well as external factors
including temperature. The rate at which the battery is discharged as well as the rate at which it
is charged will also impact the SOH of the battery. Lastly, calendar aging, or degradation of the
battery while not in use, can also contribute to the deterioration of the battery.

There are a number of ways to improve and prolong the battery life in a vehicle. We included
additional energy for conditioning the battery in our analysis for sizing the batteries and for
operating costs. Furthermore, battery size is increased by 20% to accommodate additional energy
that may be required resulting from loss of capacity over time.

LD and HD vehicles generally serve significantly different markets and use-cases, so the
battery pack design, integration, and considerations are different for HD vehicles than for LD
vehicles. This paragraph highlights a few examples of such differences. Increase in weight from
the battery pack may impact the payload of the HD vehicle. Some HD vehicles perform services
beyond transporting passengers or goods. Additional energy and power requirements from power
take-ofPv (PTO) pose additional energy demand on the battery. Unlike internal combustion
engines (ICEs), where waste heat is used to heat the interior cabins of the HD vehicle, in-cabin
thermal management during cold weather for BEVs will require additional energy from the
battery to be converted into heat; this may be of particular concern impacting the sizing of the
battery pack for buses because of their large inside volume.

1.5.1.2 Critical Raw Materials and Battery Market

In Section II.D.2.ii of the Preamble, we provided a thorough analysis of recent events in the
growth of U.S. and global battery manufacturing capacity, reviewed the role and importance of
critical minerals, and considered the outlook for critical mineral supply and demand. In that
discussion, we established a number of important points, which are reviewed briefly in this
section. Citations for the content in this section can be found in preamble Section II.D.2.ii,
except where cited here.

The Preamble discussion explained a number of key observations about the status of critical
minerals and manufacturing capacity, and the outlook for development of the supply chain in
response to industry investment and government policy:

Xlv Power take off or PTO is ancillary unit attached to some HD vehicles to perform separate work from tractive
motion; this includes moving a bucket up and down, picking up garbage, and plowing snow.

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Although much of the supply chain supporting the manufacture of ZEVs is located outside of
the U.S., more than half of battery cells and 84 percent of assembled packs in ZEVs sold in
the U.S. from 2010 to 2021 were produced in the U.S.

This suggests that ZEV production in the U.S. need not be heavily reliant on foreign
manufacture of battery cells or packs as ZEV penetration increases and domestic mineral and
cell production comes online.

A domestic supply chain for battery and cell manufacturing is rapidly forming by the actions
of stakeholders including vehicle manufacturers and suppliers who wish to take advantage of
the business opportunities that this need presents, and by vehicle manufacturers who
recognize the need to remain competitive in a global market that is shifting to electrification.

Analysis of constructed and planned plant capacity for assembly of cells and packs indicates
that battery manufacturing capacity does not appear to pose a critical constraint to expected
uptake of ZEVs, either globally or domestically.

The Department of Energy estimates that recent plant announcements for North America to
date could enable an estimated 838 GWh of capacity by 2025, 896 GWh by 2027, and 998
GWh by 2030, the vast majority of which is cell manufacturing capacity.

International production of batteries for transportation use is expected to reach 3.7 terawatt
hours (TWh) by 2030, therefore allowing for more availability of battery production to meet
any additional US domestic needs.

We also drew observations regarding which minerals are of greatest interest as a potential
constraint on ZEV production during the time frame of the rule:

Mineral demand for ICE catalyst production is relatively stable and would not be expected to
increase as a result of electrification.

Rare earths used in permanent magnet motors have potential alternatives in the use of
induction machines or other electric machine technologies that do not require rare-earth
magnets, or in the use of advanced ferrite or other advanced magnets.

On a sheer quantity basis and probably also on a value basis, battery minerals are likely to be
the most important mineral-related constraint on ZEV production during the time frame of the
rule.

Of these, the most attention is commonly given to lithium, nickel, cobalt, and graphite.

Currently, most mining and refining of these minerals occurs outside of the U.S. and they are
largely imported as refined products.

The U.S. does not lack significant deposits of these minerals, and has formerly produced
them, but relatively little mining and refining capacity is currently in operation, or remains
undeveloped.

-------
The development of mining and refining capacity in the U.S. is a primary focus of industry
toward building a robust domestic supply chain for electrified vehicle production.

For example, LG Chem has announced plans for a cathode material production facility in
Tennessee, said to be sufficient to supply 1.2 million high-performance electric vehicles per
year by 2027.

We also noted that further development of a domestic mineral supply chain will be
accelerated by the provisions of the Inflation Reduction Act (IRA) and the Bipartisan
Infrastructure Law (BIL), as well as ongoing efforts by the Executive Branch:

The IRA offers sizeable tax provisions that incentivize domestic production of batteries and
critical minerals, including production tax credits that apply to domestically produced cells,
modules, electrode active materials, and critical minerals, that can reduce battery
manufacturing cost by thirty percent or more.

The BIL provides $7.9 billion to support development of the domestic supply chain for
battery manufacturing, recycling, and critical minerals. Provisions extend across critical
minerals mining and recycling research, USGS energy and minerals research, rare earth
elements extraction and separation research and demonstration, and expansion of DOE loan
programs in critical minerals and recycling.

Through these provisions DOE is actively working to prioritize points in the domestic supply
chain to target with accelerated development, and rapidly funding those areas through
numerous programs and funding opportunities.

With BIL funding and matching private investment, more than half of the capital investment
that the Department of Energy's Li-Bridge alliance considers necessary for supply chain
investment to 2030 has already been committed.

We also noted the following observations about forecast global supplies of refined critical
minerals:

According to analyses by Department of Energy's Li-Bridge, no shortage of cathode active
material or lithium chemical supply is seen globally through 2035 under current projections of
global demand.

The International Energy Agency reached similar conclusions for cobalt and nickel, noting
that lithium would be in sufficient supply through at least 2028, before consideration of new
DOE projections of additional capacity that could further boost lithium supply beyond current
IEA and BNEF projections.

Despite recent short-term fluctuations in price, the price of lithium is expected to stabilize at
or near its historical levels by the mid- to late- 2020s, further suggesting that a critical long-
term shortage is not expected to develop.

In the context of all of the findings reviewed above, EPA recognizes that the global minerals
industry is already anticipating and preparing for accelerated growth in demand for critical
minerals resulting from already-existing expectations of greatly increased global ZEV production

-------
and sales in the future, as well as expectations of growing demand for these materials in other
areas of clean energy and decarbonization. Thus, in the context of evaluating the impact of the
proposed standards on demand for critical minerals and development of the domestic supply
chain, EPA recognizes that much of the anticipated growth in global mineral demand stems not
from the incremental effect of the proposed standards but from these ongoing forces that are
already driving the global industry to increase mineral production.

Relatedly, EPA notes that the IRA, the BIL, and ongoing activity on the part of Executive
Branch agencies are actively addressing the need for further development of the domestic supply
chain to supply growing demand for critical minerals. The provisions of the IRA and BIL were
in fact developed with the intent of growing the domestic supply chain for critical minerals and
related products and to achieve mineral security as the industry pursues clean energy technology.
Accordingly, EPA expects that the BIL and IRA will prove instrumental in meeting incremental
needs of the supply chain under the proposed standards.

The critical raw material market is not exclusive to the heavy-duty vehicle battery market,
instead it is a part of the global raw material market. Furthermore, we expect the light duty
vehicle market to be the primary consumers of lithium ion batteries. For the Light- and Medium-
Duty Multipollutant Emissions Standards Proposed Rule, we project the battery production
capacity would be slightly less than 900 GWh in MY 2030, and stabilize at around 1,000 GWh
per year for MY 2031 and beyond; in contrast, we expect HDV to require 17 GWh in 2027 and
this increase to 36 GWh by 2032. For comparison, DOE estimates plant announcements of
-1,000 GWh by 2030; furthermore, the battery market is an international market where IEA
projects 3.7 terrawatt hours (TWh) of battery globally by 2030 in their "Sustainable
Development Scenario"102 We would expect this value to increase by 2032 to meet the battery
demand in both sectors.

1.5.1.3 Additional Information on Critical Mineral Supply Chain Development

This section provides additional detailed evidence of recent developments in the growth of the
critical mineral supply chain, and other specific topics relevant to this topic. Citations for all of
the examples listed in this section may be found in a Memo to the Docket titled "DOE
Communication to EPA Regarding Critical Mineral Projects."

A number of additional U.S. government efforts are underway to accelerate lithium and
critical minerals production:

In February 2023, President Biden signed a presidential waiver of some statutory
requirements (Waiver) authorizing the use of the Defense Production Act (DP A) to allow the
Department of Defense (DoD) to more aggressively build the resiliency of America's defense
industrial base and secure its supply chains including for critical minerals and energy storage.
Since many of the investments needed in areas like mining and processing of critical minerals
can be very costly and take several years, the Waiver permits the DoD to leverage DP A Title
III incentives against critical vulnerabilities, and removes the statutory spending limitation for
aggregate action against a single shortfall exceeding $50 million. This in turn allows the DoD
to make more substantial, longer-term investments.103

In December 2022, the Blue Ribbon Commission on Lithium Extraction in California issued a
report detailing actions to support the further develop geothermal power with the potential co-

-------
benefit lithium recovery from existing and new geothermal facilities in the Salton Sea
geothermal resource area. The three owners developing projects in California may produce
600 kt/y LCE from geothermal brines around 2030.104

In June 2022, the United States formed the Minerals Security Partnership^, whose goal is to
ensure that critical minerals are produced, processed, and recycled in a manner that supports
the ability of countries to realize the full economic development benefit of their geological
endowments. The MSP will help catalyze investment from governments and the private sector
for strategic opportunities —across the full value chain —that adhere to the highest
environmental, social, and governance standards.105

Preamble II.D.2.ii mentioned $3.4 billion in DOE Loan Program projects that were recently
awarded to aid in the extraction, processing and recycling of lithium and other critical minerals
to support continued market growth. Details on these projects are provided below.

A $50M BIL grant to Lilac plans to build out domestic manufacturing capacity for the
company's patented ion-exchange technology to increase production of lithium from brine
resources with minimal environmental impact and streamlined project development timelines,
and develop domestic lithium projects.106

A $141.7M BIL grant to Piedmont Lithium plans to accelerate the construction of the
Tennessee Lithium project in McMinn County as a world-class lithium hydroxide operation,
which is expected to more than double the domestic production of battery-grade lithium
hydroxide. The project is being designed to produce lithium hydroxide from spodumene
concentrate using the innovative Metso:Outotec process flow sheet, enabling lower emissions
and carbon intensity as well as improved capital and operating costs relative to incumbent

1 07

operations.

A $150M BIL grant to Albemarle plans to support a portion of the cost to construct a new,
commercial-scale U.S.-based lithium concentrator facility at Albemarle's Kings Mountain
North Carolina location. Albemarle's "mega-flex" conversion facility would be capable of
accommodating multiple feedstocks, including spodumene from the proposed reopening of
the company's hard rock mine in Kings Mountain; its existing lithium brine resources in
Silver Peak, Nevada, and other global resources; as well as potential recycled lithium
materials from existing batteries. The facility is expected to eventually produce up to 100,000
metric tons of battery-grade lithium per year to support domestic manufacturing of up to 1.6
million EVs per year.108

A $700 million DOE loan to Ioneer Rhyolite Ridge LLC plans to help develop domestic
processing capabilities of lithium carbonate for nearly 400,000 EV batteries from the Rhyolite
Ridge Lithium-Boron Project in Esmeralda County, Nevada.109

A $2 billion DOE loan to Redwood Materials plans to construct and expand its battery
materials recycling campus in McCarran, Nevada. It would be the first U.S. facility to support

xv MSP partners include Australia, Canada, Finland, France, Germany, Japan, the Republic of Korea, Sweden, the
United Kingdom, the United States, and the European Commission.

-------
production of anode copper foil and cathode active materials in a fully closed-loop lithium-ion
battery manufacturing process by recycling end-of-life battery and production scrap and
remanufacturing that feedstock into critical materials, supporting EV production of more than
1 million per year. Redwood Materials will use both new and recycled feedstocks—comprised
of critical materials like lithium, nickel, and cobalt—to produce approximately 36,000 metric
tons per year of ultra-thin battery-grade copper foil for use as the anode current collector, and
approximately 100,000 metric tons per year of cathode active materials.110

A $375 million DOE loan to Li-Cycle plans to help finance a high efficiency, low-emission
resource recovery facility for batteries in Rochester, New York. The Li-Cycle project will use
hydrometallurgical recycling to efficiently recover battery-grade lithium carbonate, cobalt
sulfate, nickel sulfate, and other critical materials from manufacturing scrap materials and
used batteries to enable a circular economy.111

Although currently there is no alternative to lithium in manufacturing automotive BEV
batteries, several alternatives are under development that may provide an alternative, either in
automotive batteries, or in non-automotive applications whose use of these alternatives would
reduce competition for lithium in automotive applications. Citations for these examples may be
found in a Memo to the Docket titled "DOE Communication to EPA Regarding Critical Mineral
Projects."

BNEF estimates that sodium-ion batteries are scaling for use in applications that do not
require the high-performance capabilities of large EV batteries, including stationary energy
storage and 2- and 3-wheeled vehicles. Substitution from lithium to alternative chemistries
could alleviate price pressures as soon as 2026.112

A new PNNL molten salt battery design, which uses Earth-abundant and low-cost materials,
has demonstrated superior charge/discharge capabilities at lower operating temperatures while
maintaining high energy storage capacity compared to conventional sodium batteries.113

NASA's Solid-state Architecture Batteries for Enhanced Rechargeability and Safety
(SABERS) research for aerospace applications will likely have spin-off benefits for the
automotive sector. As lithium-ion based liquid electrolytes are not suitable for aircraft, the
development of a scalable, solid state battery that is safer, more energy dense, and capable of
faster charging has high commercialization potential in on-road vehicles applications, and can
reduce lithium demand.114'115

Finally, a large amount of research and development is taking place to increase circularity and
effective use of lithium and critical minerals. Beyond commercial technologies, continued
research and development with industry and academia through the US Automotive Battery
Consortium (USABC), Critical Minerals Institute (CMI), and ARPA-E will expand the recycling
and recovery of lithium to help expand the use of unconventional supplies to help pace the
growing demand for EVs:

A $2M USABC grant to American Battery Technology Company (ABTC) in Fernley, Nevada
will help develop a recycling development program to demonstrate a scaled, fully-domestic,

-------
integrated processing cycle for the universal recycling of large format Li-ion batteries in
coordination with partners in the battery supply chain.116

The CMI's EC-LEACH project successfully demonstrated a lOx scale-up of electrochemical
leaching for lithium-ion batteries black mass, e-waste comprised of crushed and shredded
battery cells, with a capacity up to 500 g/day, achieving over 96% leaching efficiency for all
metals. The scale up demonstrated leaching under higher voltage while maintaining lower
currents and used conventional power electronics.117'118

$39 million in ARPA-E funding for the Mining Innovations for Negative Emissions Resource
Recovery (MINER) program will help develop market-ready technologies that will increase
domestic supplies of critical elements, including copper, nickel, lithium, cobalt, rare earth
elements, that are required for the clean energy transition. The MINER program will fund
research that increases the mineral yield while decreasing the required energy, and subsequent
emissions, to mine and extract energy-relevant minerals.119

1.5.2 BEV Safety Considerations

BEVs receive, store, and utilize large amounts of electrical energy. The stored electrical
energy resides as chemical energy in the battery. This electrical and chemical energy must be
safely controlled during charging, while held by the battery and other high voltage components,
and when providing vehicle power. The electrical energy must be isolated from humans to
prevent shock. The electrical energy also needs isolation from the vehicle so that a short does not
allow harmful amounts of electricity to move through and damage other components. Finally, the
chemical energy held in the battery must be managed so it is not allowed to generate excessive
heat that could harm surrounding components or ignite a fire.

Both LD and HD BEVs are progressing from 400V systems to 600V and higher.120 Although
many LD BEV are 400V and many trucks and buses 600V, there is no consistent voltage
difference between LD and HD. Both categories are clearly high voltage and carry high voltage
risk, as high voltage is considered to be 60V DC up to 1,500V DC.121 The safety of a HD BEV
benefits from the significant work conducted in the LD BEV sector addressing the BEV risk
factors. Risk factors related to battery capacity will generally be greater for HD BEVs, as they
often, though not always, need to be larger and do more work than the LD BEV.

HD BEV systems must always maintain safe operation. As with any onroad vehicle, they
must be robust during temperature extremes as well as rain and snow. The systems must be
designed for reasonable levels of immersion, including immersion in salt water or brackish
water. BEV systems must be designed to be crashworthy and limit damage that compromises
safety. If the structure is compromised by a severe impact, the systems must provide first
responders with a way to safely conduct their work at an accident scene. The HD BEV systems
must be designed to ensure the safety of users, occupants, and the general public in their vicinity.

1.5.2.1 Charging Safety

Charging involves electricity flowing into the vehicle at power levels that are capable of
harming people and equipment. To ensure safety, the vehicle and charging system must:122

-------
• keep people isolated from the high voltage electricity in the vehicle and charger. (High
voltage must not be present within 1 second of charger disconnect.);

• establish and monitor a vehicle and equipment ground path;

• monitor the process for isolation issues and shorts;

• exchange information between the vehicle and charging equipment;

• indicate if the vehicle is in active drive mode; and

• notify the operator if action is required to complete charging safely.

Complexities with the battery design and reactions occurring in the battery cells drive the
need for feedback from the battery to the charging system. This charge management is handled
within the vehicle with AC chargers or within the DC charging equipment that is external to the
vehicle. The safety of HD vehicle charging systems has benefitted from the more extensive LD
vehicle development and deployment. Some of the industry codes and standards that guide safe
deployment of BEV charging systems are:

• Society of Automotive Engineers (SAE) J-1772, conductive charging

• SAE J-2954/2, inductive charging

• SAE J-3072, grid support from the EV

• SAE J-3271, megawatt charging system (up to 1500V/3000A) requirements

Other related standards have been developed by NHTSA,XV1 International Electrotechnical
Commission (IEC), National Electric Code (NEC) and Underwriters Laboratories (UL).

1.5.2.2 Battery Safety

BEV batteries receive, store, and discharge electrical power. BEV batteries require both the
proper physical design and the proper controls (or battery management system) to allow them to
safely accept and deliver power for the life of the vehicle. The battery design must provide
external short circuit protection, over and under charge protection and over temperature
protection. Some of the design and controls standards that ensure BEV can accept and deliver
power robustly, without overheating or failing, are shown below.

• SAE J2464-202108, safety and abuse testing at the component level

• SAE J2929-201102, safety standard for lithium-based cells

• NHTSA DOT 49 CFR 571.305 EV Safety is adding battery requirements per RIN: 2127-
AM43

Other related standards have been developed by IEC, International Standards Organization
(ISO) and UL.

XV1 For example "DC and AC Charging Safety Evaluation Procedure Development, Validation, and Assessment".
Published Date : 2019-07-01 Report Number : DOT HS 812 778 Available online:
http s: //ro sap. ntl. bts. go v/view/dot/41933

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1.5.2.3 Battery Protection from the Environment, Road Hazards, and Immersion

The BEV battery must be designed to handle external challenges. A HD BEV and its battery
will be exposed to vibration, temperature extremes, temperature cycling, water, and mechanical
impact from items such as road debris. The water may arrive as rain, snow, and/or soaking rains
that later freeze. The vehicle may drive through or be exposed to water with varying levels of salt
that will be a much better conductor of electricity and can be corrosive over time. The batteries
must hold up to impact from foreseeable types of road debris. The standards that address these
conditions are SAE J2464, safety and abuse testing, and others from IEC and ISO.

1.5.2.4 BEV Safety Regarding Crash and Maintenance

The crash test performance of today's LD electric vehicles is demonstrating that they are at
least as safe as ICE vehicles.123 This conclusion is based on a 2021 report and assessment of
LDV by the Insurance Institute for Highway Safety (IIHS). IIHS found that driver and passenger
injury claims from 2011 to 2019 were 40% lower for electric vehicles versus "identical"
conventional vehicles.124

For HD BEVs to uphold battery/electrical safety during and after a crash, they are designed to
maintain high voltage isolation, prevent leakage of electrolyte and volatile gases, maintain
internal battery integrity, and withstand external fire that could come from the BEV or other
vehicle(s) involved in a crash. The internal battery integrity is important to prevent fire risk from
developing within the battery over time. Standards driving design and process for optimizing
crash and post-crash safety have been completed by IEC and ISO as well as:

• National Highway Traffic Safety Administration (NHTSA) FMVSS 305, electrolyte
spillage and electrical shock protection

• NHTSA DOT HS 812 789, post-crash stranded energy tools and procedures

• SAE J1766, crash integrity testing

• SAE J2990, first and second responder recommended practice

An important aspect of crash safety is knowledge and training for first responders and those
handling crashed BEV vehicles. First responders must know how to locate and apply high
voltage disconnects. They must also know to check for high voltage sources so they can avoid or
drain those energy sources. This is especially true if they are in contact with the vehicle to free
an occupant. Real world operation and testing has shown that large amounts of water (2,600
gallons for a 600 lbs li-ion battery) is needed for BEV firefighting to cool the batteries and
eliminate the risk of fire.125 Safe storage of crashed vehicles is critical as internal battery failure
reactions may occur days after the crash and reignite.

Performing standard maintenance on BEVs leads to new or increased risk compared to ICE
vehicles and requires corresponding safety training due to the following:126

• the presence of high voltage components and cabling capable of delivering a fatal electric
shock;

• the storage of electrical energy with the potential to cause explosion or fire;

-------
• components that may retain a dangerous voltage even when a vehicle is switched off;

• electric motors or the vehicle itself that may move unexpectedly due to magnetic forces
within the motors;

• manual handling risks associated with battery replacement;

• the potential for the release of explosive gases and harmful liquids if batteries are
damaged or incorrectly modified;

• the possibility of people being unaware of vehicles being in motion because when they
are electrically driven they are silent in operation;

• the potential for the electrical systems on the vehicle to affect medical devices such as
pacemakers.

While the systems have safety guards and checks, personnel must be able to verify that those
systems are operating correctly. Maintenance personnel will need appropriate personal
protective equipment (PPE) and instructions on its use.

1.5.3 BEV System Integration

While both BEV and ICE vehicle technologies have many components in common, there are
also many different components as described in this Chapter 1 and Chapter 2. The arrangement
of a vehicle's components can have a significant impact on its energy efficiency, volumetric and
gravimetric payload capacity, and cost. Currently, some BEVs are designed very similarly to
comparable ICE vehicles, while other BEVs are designed more from a "ground-up" approach,
allowing them to better take advantage of the characteristics unique to BEVs, such as the
flexibility of placement in battery mass and the modularity of battery pack sizes.

HD vehicles fill a diverse set of requirements, necessitating different approaches to BEV
component integration. This chapter gives a few examples of BEV systems and integration to
illustrate the current state of HD BEV design and provide a projection of potential future
evolution that we have assessed and are proposing is feasible during the time frame considered in
this proposed rulemaking.

1.5.3.1 Integration into Existing ICE Vehicle Design

Some HD vehicle outfitters take existing vehicles and repower them by replacing some or all
of the powertrain with newer components.™1 This allows the vehicle owner to update a vehicle
without purchasing an entirely new vehicle, thus saving cost. This has traditionally been done
while maintaining the type of powertrain (e.g., compression ignition ICE), but may also be done
to convert ICE vehicles to BEVs as Complete Coach Works does with buses, as shown in Figure
1-5. Additional outfitters taking this approach include Unique Electric Solutions (UES),127 Revo
Powertrains,128 and Blue Bird.129

xvu This concept of replacement of ICE with BEV components can be applied to new vehicles without a complete
vehicle re-design. Our standards would not apply to in-use products, so do not require repowering.

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Figure 1-5 Complete Coach Works' process for repowering conventional buses to battery electric buses130

Complete Coach Works repowers buses by stripping the chassis down to the frame; removing
all interior and exterior components; removing the diesel engine; installing a battery electric
powertrain; installing light-weight flooring, seats, and windows and energy-efficient lighting;
and conducting a final inspection. In the example shown in Figure 1-5, the bus was renovated
beyond a repower by adding in lightweight and energy-efficient components to reduce the
energy demands on the battery. Such an approach may have certain advantages and
disadvantages. For example, the cost of such a bus conversion would likely be lower than the
cost of purchasing a new battery electric bus, but the placement and size of the powertrain
components would be constrained to the space that the diesel engine originally occupied. This
latter consideration may be limiting for some of the components and specifications, e.g., the
capacity of the battery packs.

1.5.3.2 HD Vehicles with ICE and BEV Components

Spartan Emergency Response offers a fire truck called Vector, which the company purports to
be an electric fire truck.131 It is capable of all-electric operation for both driving and pumping
water using its sizeable 327 kWh battery. The vehicle also comes with a range-extending option
where the ICE that can recharge the battery at low charge; in this version, the vehicle functions
similar to that of a series hybridxvm. While this fire truck does not benefit from a fully electric
vehicle's omission of an engine and associated components, the Vector fire truck was designed
to take advantage of the battery's mass by placing them such that the truck has a lower center of
gravity, which provides better handling and maneuverability, as shown in Figure 1-6. This design
decision demonstrates one way that an electric vehicle could provide an advantage over a
comparable ICE vehicle. Additional manufacturers of FID vehicles that include ICE components

®nl In a series hybrid, the engine is used to charge the battery which in turn powers the e-motor. The engine does
not directly drive the powertrain using a transmission.

-------
but may also operate in all-electric modes include Kenworth,132 US Hybrid,133 Hyliion,134 and
Pierce Manufacturing.135

Low Center of Gravity Battery Placement

Provides better handling, less sway while cornering and is farther from cab occupants in a crash

Figure 1-6 Spartan Emergency Response places the battery packs of their Vector fire truck strategically to

improve handling

1.5.3.3 Integration into Vehicle Ladder Frame

Bollinger Motors approaches BEV design by constraining the battery packs and other BEV
powertrain components to the ladder frame of their vehicles,136 like trends in LD BEV design.
This provides three advantages over an ICE vehicle, as illustrated in Figure 1-7. First, as shown
in Figure l-7(a), the relatively small size of the e-motor allows Bollinger Motors to bring the cab
forward, which improves visibility and increases cargo space. Second, as depicted in Figure
l-7(b), this design provides a literal platform upon which to tailor the BEV to each customer's
needs. Third, as shown in Figure J-7(e), the battery capacity can be easily adjusted with the same
general layout to accommodate different energy demands for a range of vehicles across duty
cycles and gross weight vehicle rating (GVWR), which allows Bollinger Motors to reduce some
of the engineering costs. Other manufacturers placing battery packs in the ladder frame of FID
BEVs include Volvo,137 Peterbilt,138 Navistar,139 and Xos.14"

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'£3 1

lT i-

aer*

(c)

CLASS 3

GVWR 14,000

CLASS 4

GVWR 16,000

CLASS 5

GVWR 19,500

CLASS 6

GVWR 26,000

Figure 1-7 Bollinger Motors' commercial electric trucks, (a) Cab-forward design increases cargo space over
conventional cabs, (b) Platform enables the trucks to be upfit to fill a wide variety of purposes, (c) Battery

packs in the ladder frame are flexible enough

1.5.4 BEV Ancillary Systems

1.5.4.1 Heating, Ventilation, and Air Conditioning (HVAC)

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The use of energy to heat or cool the cabin of the vehicle can require energy from a power
source, typically the battery itself. As a result of the large interior cabins of some heavy-duty
vehicles, such as a school bus, this may require a heat pump. Cabin heat can be provided by
using a positive temperature coefficient (PTC) electric resistance heater. PTC electric heaters
convert electrical energy into thermal energy. PTC energy conversion efficiency from electrical
to thermal energy is 100 percent.

Heat pumps provide both heat and air conditioning (A/C) by utilizing a thermodynamic cycle
to move thermal energy, rather than directly converting energy from another form. Heat pump
system hardware and operation is fundamentally the same as a standard air conditioner. The
addition of a reversing valve can change the direction in which thermal energy is moved. Heat
pump heating efficiency is very high, normally exceeding 100 percent because they can move
more thermal energy than the amount of electrical energy that is consumed to move it. Efficiency
is dependent on ambient air temperature. Heat pump efficiency is described by the coefficient of
performance (COP), a ratio of the useful thermal energy (heat) provided by the system, to the
electrical energy that it consumed. Modern heat pumps achieve a COP ranging from 1.0, equal to
100 percent efficiency in very low ambient temperatures, to 4.0 or higher - 400 percent or higher
efficiency, at moderate temperatures. In other sectors, heat pumps are currently and increasingly
in use for water heating141, industrial process heat142, LD electric vehicles143, and international
market heavy-duty vehicles144. Rapid development of heat pumps in established and rising
markets indicate both the appropriateness and heightened interest in adopting the technology.
Heat pump manufacturers are developing and commercializing residential systems that operate
with a minimum efficiency of 210 percent-240 percent at 5°F, and operating as low as -15°F (at
100 percent efficiency).145 With a growing HD BEV market, we expect HVAC manufacturers
will develop and expand their vehicle heat pump products.

Vehicles with a particularly high heating load or extended idle requirement may use auxiliary
cabin heat systems. Fuel operated heaters (FOH), also known as direct fired heaters (DFH), are
small standalone air or coolant heaters that combust diesel or gasoline solely as the source of
heat. Emissions from combustion are directly exhausted outside the vehicle.

FOHs may be used in ZEV applications operating in extreme low temperatures, or where a
reduction in driving range is unacceptable. Considering the applications most appropriate for
electrification in MYs 2027 through 2032, the sustainability goals of both fleets and OEMs
purchasing electric vehicles, and the high efficiency of heat pumps and sensitivities of FOH
emissions, we believe that it is unlikely that FOH will be the primary solution for cabin heat.

1.5.4.2 Electric Power Take Off

Vehicles equipped today with an electric power take off (ePTO) are a small portion of the
overall heavy-duty industry and are typically equipped on utility vehicles.X1X The ePTO's are
powered by the batteries for a period of time, with the vehicle engine off, until the battery charge
is depleted to the minimum allowable level. The vehicle's ICE then restarts to run the ePTO,
charge the ePTO battery pack, or both. Some systems also have a plug-in option to recharge the
batteries (plug-in hybrid). Three manufacturers offer these systems on a range of vocational

X1X PTO units are auxiliary power units used to power other work required by the HDV; these work units include
lifting buckets in bucket trucks, lifting garbage cans or mixing cement.

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vehicles. These vehicles are summarized in Table 1-16. Two all-electric vehicles with ePTOs
are also listed - one for utility and one for refuse trucks.

Table 1-16 Current Electronic Power Take Off Market Offerings

Make

Model

Vehicle Type

Altec Industries

JEMS LE — plug-m/hybnd14®

Utility, Digger Derricks, Service
Body Lrucks

Altec Industries

JEMS SE - plug-in h\ brid'

Utility, Digger Derricks, Service
Body Trucks

Altec Industries

All Electric146

Utility

Odyne Systems, LLC

ePLO- plug-in hybrid '

Utility, Compressors, Dump
Lrucks, Septic Trucks, etc.

Mack

LR Electric148

Refuse Lrucks

1.5.5 BEY Market

The current heavy-duty market offers battery electric vehicles available for sale as both new
design BEVs and through conversions of ICE vehicles to BEVs. This market has been growing
since MY 2018 and is projected to reach about 200 models of heavy-duty battery electric trucks
by MY 2024,xx see Figure 1-8 for a summary of the number of battery electric heavy-duty trucks
available by model year as identified by literature review.

Heavy-Duty ZEV Models Available in the U.S. per Model

Year

250

200 _

. I I I I I

2018 2019 2020 2021 2022 2023 2024

Model Year

Figure 1-8 Heavy-Duty Electric Trucks Available in the U.S. by Model Year

A list of battery electric heavy-duty trucks available to the public through MY 2024 is in
Table 1-17.

Table 1-17 Models of Battery Electric Heavy-Duty Vehicles through 2024

'm Miller, Neil. Memorandum to docket EPA-HQ-OAR-2022-0985. "Heavy-Duty £EV Models Available in the US
through MY2024." March 2023.

-o
o

Ol
_Q

-------
Make

Model

Vehicle
Type

Weight
Class

New Design or Existing
Design Conversion

First
Model
Year

ABC Companies

Vicinity Lightning

EV149

Transit Bus

Class 6;
Class 7

New

2021

ARBOC
Specialty
Vehicles

Equess Charge150

Transit Bus

Class 7;
Class 8

New

2021

Arrival

Van151

Panel Van

Class 4

New

2021

Autocar

E-ACTT152

Yard Truck

Class 8

New

2021

Battle Motors

LET153

Refuse

Class 6;
Class 7;
Class 8

New

2022

Battle Motors

LET 2154

Refuse

Class 7

New

2022

Blue Arc

EV155

Panel Van

Class 3;
Class 4;
Class 5;
Class 6

New

2022

Blue Bird

Electric All
American Bus156

Shuttle Bus;
Transit Bus

40-59
ft; Class
8

New

2019

Blue Bird

Electric All
American Bus156

Shuttle Bus;
Transit Bus

40-59
ft; Class
7

New

2019

Blue Bird

Electric All
American School

Bus156

Public
School Bus

Class 8

New

2019

Blue Bird

Electric All
American School

Bus156

Public
School Bus

Class 7

New

2019

Blue Bird

Electric Vision

Bus157

Shuttle Bus;
Transit Bus

30-39
ft; Class
6; Class
7

New

2019

Blue Bird

Electric Vision
School bus157

Public
School Bus

Class 6;
Class 7

New

2020

Blue Bird

Micro Bird G5158

Public
School Bus

Class 4

Conversion

2020

Bollinger Motors

Deliver e159

Step Van

Class 5

New

2020

Bollinger Motors

B4 Chass-e Cab160

Chassis Cab

Class 4

New

2021

Brightdrop

EV600161

Panel Van

Class 3

New

2023

BYD Motors

6F162

Straight
Truck

Class 6

New

2020

BYD Motors

6F/6F+162

Straight
Truck

Class 6

New

2021

BYD Motors

6R163

Refuse

Class 6

New

2020

BYD Motors

8R1M

Refuse

Class 8

New

2019

BYD Motors

8TT165

Tractor

Class 8

New

2019

BYD Motors

8Y166

Yard Truck

Class 8

New

2019

BYD Motors

C10M167

Coach Bus

> 40 ft;
Class 8

New

2020

BYD Motors

C10MS168

Coach Bus

> 40 ft;
Class 8

New

2019

BYD Motors

C6M169

Coach Bus

20-24
ft; Class

New

2019

-------
Make

Model

Vehicle
Type

Weight
Class

New Design or Existing
Design Conversion

First
Model
Year

4; Class
5

BYD Motors

C8M170

Coach Bus

30-39
ft; Class
8

New

2019

BYD Motors

C8MS171

Coach Bus

30-39
ft; Class
8

New

2021

BYD Motors

C9M172

Coach Bus

30-39
ft; Class
8

New

2019

BYD Motors

K11M173

Transit Bus

> 40 ft;
Class 8

New

2019

BYD Motors

K7M174

Transit Bus

30-39
ft; Class
7

New

2020

BYD Motors

K7M-ER175

Shuttle Bus;
Transit Bus

30-39
ft; Class
8

New

2020

BYD Motors

K8M176

Transit Bus

30-39
ft; Class
8

New

2019

BYD Motors

K9M177

Transit Bus

30-39
ft; Class
8

New

2019

BYD Motors

K9MD178

Transit Bus

30-39
ft; Class
8

New

2019

BYD Motors

Type D School
Bus179

Public
School Bus

Class 8

New

2021

Canadian
Electric Vehicles

Airport Service
Vehicle180

Airport
Service
Vehicle

Conversion

2020

Canoo

MPDV l181

Panel Van

Class 3

New

2022

Canoo

MPDV 2181

Panel Van

Class 4

New

2022

CityFreighter

CF1182

Step Van

Class 4;
Class 5

New

2022

Complete Coach
Works

ZEPS183

Transit Bus

Class 8

Conversion

2020

Dulevo

D.zero2184

Street
Sweeper

New

2020

ElDorado
National

AXESS 32185

Transit Bus

Class 8

New

2022

ElDorado
National

AXESS 35185

Transit Bus

Class 8

New

2022

ElDorado
National

AXESS 40185

Transit Bus

Class 8

New

2022

Envirotech Drive
Systems
Incorporated

C Series186

Panel Van

Class 4

New

2019

-------
Make

Model

Vehicle
Type

Weight
Class

New Design or Existing
Design Conversion

First
Model
Year

Envirotech Drive
Systems
Incorporated

C Series Cutaway,
Urban Cab Over187

Straight
Truck

Class 4

New

2019

Envirotech Drive
Systems
Incorporated

Urban Cab Over188

Straight
Truck

Class 3

New

2020

Ford

eTransit189

Panel Van

Class 4

New

2022

Freightliner

eCascadia190

Tractor

Class 8

New

2022

Freightliner

eM2191

Straight
Truck

Class 6;
Class 7

New

2023

Freightliner

MT50e192

Step Van;
Straight
Truck

Class 5

New

2020

Gillig

29193

Transit Bus

25-29
ft; 30 -
39 ft;
Class 8

New

2020

Global
Environmental
Products

M3EV194

Street
Sweeper

New

2020

Global
Environmental
Products

M4EV195

Street
Sweeper

New

2020

GreenPower
Motor Company

BEAST196

Public
School Bus

Class 8

New

2020

GreenPower
Motor Company

AV Star197

Shuttle Bus

Class 4

New

2020

GreenPower
Motor Company

EV Star CarGo198

Panel Van

Class 4

New

2019

GreenPower
Motor Company

EV Star CarGo
Plus199

Straight
Truck

Class 4

New

2021

GreenPower
Motor Company

EV Star CC200

Straight
Truck

Class 4

New

2021

GreenPower
Motor Company

EV Star201

Shuttle Bus

Class 4

New

2020

GreenPower
Motor Company

EV Star Plus202

Paratransit;
Shuttle Bus

Class 4

New

2020

GreenPower
Motor Company

EV250203

Transit Bus

30-39
ft; Class
8

New

2019

GreenPower
Motor Company

EV350204

Transit Bus

40-59
ft; Class
8

New

2019

GreenPower
Motor Company

EV550205

Transit Bus

> 40 ft;
Class 8

New

2019

GreenPower
Motor Company

SYNAPSE 72206

Public
School Bus

Class 8

New

2019

GreenPower
Motor Company

SYNAPSE207

Shuttle Bus;
Transit Bus

30-39
ft; Class
8

New

2019

Hino

XL8208

Tractor

Class 8

New

2023

Hino

XL7208

Tractor

Class 7

New

2023

-------
Make

Model

Vehicle
Type

Weight
Class

New Design or Existing
Design Conversion

First
Model
Year

Hino

M52°8

Straight
Truck

Class 5

new

2023

Hometown
Manufacturing

Villager209

Transit Bus

Class 6;
Class 7

New

2021

Hometown
Manufacturing

Mainstreet210

Transit Bus

Class 6;
Class 7

New

2021

Hometown
Manufacturing

Streetcar211

Transit Bus

Class 7;
Class 8

New

2021

Hometown
Manufacturing

Transit Bus

Class 6;
Class 7

New

2021

Hometown
Manufacturing

Commuter213

Transit Bus

Class 7;
Class 8

New

2021

Hometown
Manufacturing

Urban214

Transit Bus

Class 7;
Class 8

New

2021

Hyundai

Electric City215

Transit Bus

Class 7

New

2020

IC Bus

CE Electric216

Public
School Bus

Class 7

New

2021

Iona

Van217

Panel Van

Class 3

New

2020

Kalmar

T2E+218

Yard Truck

Class 8

New

2020

Kenworth

K270E219

Straight
Truck

Class 6

New

2020

Kenworth

K370E219

Straight
Truck

Class 7

New

2020

Kenworth

T680E220

Tractor

Class 8

New

2020

Lightning
Systems

Transit Bus221

Transit Bus

Class 6

Conversion

2020

Lightning
Systems

Transit Cargo
Van222

Panel Van

Class 4

Conversion

2020

Lightning
Systems

ZEV4223

Box Truck

Class 4

Conversion

2020

Lightning
Systems

ZEV4224

Paratransit;
Shuttle Bus

25-29
ft; Class
4

Conversion

2019

Lightning
Systems

ZEV4/ZEV5225

Step Van

Class 4;
Class 5

Conversion

2019

Lightning
Systems

ZEV5/ZEV6226

Straight
Truck

30-39
ft; Class
5; Class
6

Conversion

2019

Lion Electric

Lion6227

Straight
Truck

Class 6

New

2021

Lion Electric

Lion8P ASL227

Refuse

Class 8

New

2021

Lion Electric

Lion8P227

Straight
Truck

Class 8

New

2019

Lion Electric

Lion8P Rel227

Refuse

Class 8

New

2021

Lion Electric

Lion8T227

Tractor

Class 8

New

2021

Lion Electric

Bucket Truck227

Bucket
Truck

Class 8

New

2021

Lion Electric

Lion A228

Public
School Bus

Class 6

New

2019

Lion Electric

LionC229

Public
School Bus

Class 6;
Class 7

New

2019

-------
Make

Model

Vehicle
Type

Weight
Class

New Design or Existing
Design Conversion

First
Model
Year

Lion Electric

LionD230

Public
School Bus

Class 8

New

2019

Lion Electric

LionM231

Paratransit

Class 6

New

2020

Mack Trucks

LR232

Refuse;
Straight
Truck

Class 8

New

2021

Mercedes Benz

eCitaro233

Transit Bus

Class 8

New

2021

Mercedes Benz

eACTROS234

Straight
Truck

Class 8

New

2021

Mitsubishi

eCANTER235

Straight
Truck

Class 4

New

2019

Motiv Power
Systems

E-450236

Straight
Truck

Class 4

Conversion

2021

Motiv Power
Systems

F-53237

Shuttle Bus

Class 6

Conversion

2020

Motor Coach
Industries

D45 CRTe LE238

Coach Bus;
Shuttle Bus;
Transit Bus

40-59
ft; Class
8

New

2020

Motor Coach
Industries

J4500e238

Coach Bus;
Shuttle Bus;
Transit Bus

40-59
ft; Class
8

New

2020

Navistar

eMV239

Straight
Truck

Class 6;
Class 7

New

2021

New Flyer

XCELSIOR Charge

NG240

Transit Bus

35, 40,
60 ft;
Class 7;
Class 8

New

2021

Nikola

Tre241

Tractor

Class 8

New

2021

Nova Bus

LFSe242

Transit Bus

Class 8

New

2018

Nova Bus

LFSe+243

Transit Bus

Class 8

New

2021

Optimal Inc

SI244

Shuttle Bus

Class 5

Conversion

2021

Optimal Inc

El245

Chassis Cab

Class 5

Conversion

2021

Orange EV

T-Series246

Yard Truck

Class 8

New

2020

Peterbilt

220EV247

Straight
Truck

Class 6;
Class 7

New

2021

Peterbilt

520EV247

Refuse;
Straight
Truck

Class 8

New

2021

Peterbilt

579EV247

Tractor

Class 8

New

2021

Phoenix

Zeus 400248

Shuttle Bus

25-29
ft; Class
4

New

2019

Phoenix

Zeus 500248

Straight
Truck

Class 4

New

2020

Phoenix

Zeus 600249

Public
School Bus

Class 4

New

2019

Proterra

ZX5+ 3 51250

Transit Bus

35 ft;
Class 8

New

2021

Proterra

ZX5+ 3 51250

Transit Bus

35 ft;
Class 8

New

2021

Proterra

ZX5+ 40'251

Transit Bus

40 ft;
Class 8

New

2021

-------
Make

Model

Vehicle
Type

Weight
Class

New Design or Existing
Design Conversion

First
Model
Year

Proterra

ZX5+ 40'251

Transit Bus

40 ft;
Class 8

New

2021

Proterra

ZX5 MAX251

Transit Bus

40 ft;
Class 8

New

2021

Proterra

ZX5 MAX251

Transit Bus

40 ft;
Class 8

New

2021

Rivian

R1T Step Van252

Step Van

Class 5

New

2021

ROUSH
CleanTech

F-650253

Straight
Truck;
Utility

Class 6

New

2020

Scania

NXT254

Transit Bus

Class 8

New

2023

SEA Electric

Hino 195255

Straight
Truck

Class 4;
Class 5

Conversion

2020

SEA Electric

Hino GH256

Straight
Truck

Class 8

Conversion

2020

SEA Electric

Hino FM257

Refuse Truck

Class 8

Conversion

2020

SEA Electric

Hino FG258

Straight
Truck;
Utility

Class 5,
Class 6,
Class 7

Conversion

2021

SEA Electric

Hino FE259

Refuse

Class 5,
Class 6,
Class 7

Conversion

2021

SEA Electric

Hino 917260

Straight
Truck

Class 4;
Class 5

Conversion

2020

SEA Electric

Isuzu FRR261

Straight
Truck

Class 5,
Class 6,
Class 7

Conversion

2020

SEA Electric

Isuzu FSD262

Straight
Truck

Class 5,
Class 6,
Class 7

Conversion

2020

SEA Electric

Isuzu FTR263

Straight
Truck

Class 5,
Class 6,
Class 7

Conversion

2020

SEA Electric

Isuzu NLR264

Straight
Truck

Class 3,
Class 4

Conversion

2020

SEA Electric

Isuzu NNR265

Straight
Truck

Class 3,
Class 4

Conversion

2020

SEA Electric

Isuzu NPR266

Straight
Truck

Class 4;
Class 5

Conversion

2020

SEA Electric

Isuzu NRR267

Straight
Truck

Class 5,
Class 6,
Class 7

Conversion

2020

SEA Electric

Ford F-59268

Panel Van

Class 6;
Class 7

Conversion

2021

SEA Electric

Ford F-650269

Straight
Truck;
Utility

Class 6

Conversion

2020

SEA Electric

Ford F-750269

Straight
Truck;
Utility

Class 7

Conversion

2020

SEA Electric

Ford Transit270

Panel Van;
Step Van

Class 3

Conversion

2020

-------
Make

Model

Vehicle
Type

Weight
Class

New Design or Existing
Design Conversion

First
Model
Year

SEA Electric

300271

Straight
Truck;
Utility

Class 4;
Class 5

Conversion

2020

SEA Electric

500272

Straight
Truck;
Utility

Class 6;
Class 7

Conversion

2020

SEA Electric

SV6273

Straight
Truck

Class 6

New

2023

SEA Electric

Type A School bus,
Chevy Van274

Public
School Bus

Class 4

Conversion

2023

SEA Electric

Type C School
Bus275

Public
School Bus

Class 6

Conversion

2023

Terraline

LH1276

Tractor

Class 8

New

2024

T erberg

YT203-EV277

Yard Truck

Class 8

New

2020

Tesla

Semi278

Tractor

Class 8

New

2024

Thomas Built

eC2 Jouley279

Public
School Bus

Class 7

New

2019

US Hybrid

Transit280

Transit Bus

Class 3

Conversion

2022

Van Hool NV

CX45E281

Coach Bus;
Shuttle Bus;
Transit Bus

Class 8

New

2020

Van Hool NV

TDX25e282

Coach Bus

Class 8

New

2023

Volvo

VNR283

Tractor

Class 8

New

2021

Volvo

VNR

Straight
Truck

Class 8

New

2021

Volvo

7900 Electric284

Transit Bus

Class 8

New

2023

Workhorse
Group Inc.

W750285

Step Van

Class 3

New

2020

XL Electric

F-600286

Refuse

Class 6

Conversion

2022

Xos

SV05287

Step Van

Class 6

New

2022

Xos

HDXT288

Tractor

Class 8

new

2022

Xos

MDXT289

Straight
Truck

Class 6;
Class 7

New

2022

Hexagon

Purus eM2290

Straight
Truck

Class 6;
Class 7

Conversion

2021

Zeus

Electric Chassis291

Straight
Truck

Class 5;
Class 7

New

2023

1.5.5.1 Purchase Commitments of Battery Electric Vehicles

A report by The Environmental Defense Fund (EDF) summarized several publicly announced
heavy-duty electric vehicle purchase commitments during 2022.292 These announcements can be
found at the references in Table 1-18 below. These announcements were made prior to the
passage of the Inflation Reduction Act and therefore do not include purchase commitments that
may result from consideration of the various tax incentives and other incentives that currently are
available in the market, as summarized in chapter 1.3.2 of this document.

Table 1-18 List of HD BEV Purchase Commitments Compiled by EDF (2022)292

-------
Fleet

EVs Deployed
/ Ordered

Vehicles
Delivered

Vehicle Type

Vehicle Model

4 Gen Logistics

Class 8 Tractor

-Kenworth T680E

A. Duie Pyle Inc.

Yes

Class 4 Box Truck

-FUSO eCanter

A.P. Moller-Maersk

300

Class 8 Tractor

-Einride AB

A&R Logistics

Yes

Class 8 Tractor

-Peterbilt Model 579EV

AE Cargo Group Inc,

Y ard tractor

N/A

AJR Trucking

Class 8 Tractor

-Kenworth T680E

Albertsons Cos.

Partially

Class 8 Tractor

-10 Tesla semi trucks
-2 Volvo VNR Electric truck

Alco

Yes

Terminal Tractor

-Orange EV T-Series

Alsco

Yes

Class 4 Step Van

-EPIC F-59 F

Amazon

102,500

Partially

Class 2b Cargo Van
Class 8 Tractor
Class 6 Tractor
Class 2b Delivery Van

-100,000 Rivian Cargo Van
-1250 Lion Electric
-1250 Lion Electric
-TBA BEV ProMaster

Amherst County

Class 8 Tractor

-N/A

Anderson DuBose

Yes

Terminal Tractor

-Orange EV

Anheuser-Busch Cos.

841

Partially

Class 8 Tractor

-21 BYD 8TT
-800 Nikola Fuel Cell
-40 Tesla semi trucks

ARAMARK and Operating
Companies

Yes

Class 5 Step Van

-Motiv Power Systems F-59

Benore Logistic Systems

Yes

Class 8 Tractor

-Peterbilt Model 579EV

Best Transportation

Terminal tractors

N/A

Bettaway Beverage
Distributors Inc.

Distribution tractors

N/A

Biagi Bros. Inc.

Yes

Class 8 Tractor

-Peterbilt 579EV

Bimbo Bakeries USA and
Operating Companies

105

Yes

Class 5 Step Van
Class 5 Step Van

-100 Motiv F-59
-5 Motiv F-59

Black Horse Carriers

Yes

Class 8 Tractor

-Freightliner eCascadia

Blue Earth Compost, Inc

Class 5 Step Van

-N/A

Borough of Bergenfield

Class 8 Refuse

N/A

C&V Contractors

Yes

Class 4 Truck

-Pheonix Motorcars Zeus
500

Camrett Logistics

Yes

Class 8 Tractor

-Volvo VNR

City Furniture

Partial

Terminal Tractor
Class 8 Tractor

-1 Kalmar Ottawa Electric
-5 Tesla Semis

City of Englewood

Class 8 Refuse

N/A

City of Hyattsville

Class 6 Refuse

-BYD 6R

City of Jersey City

Yes

Class 6 Refuse

-BYD 6R

City of Los Angeles Center
for Green Innovation

Yes

Class 6 Box Truck

-ROUSH CleanTech's Ford
F-650

City of Madison Fire
Department

Yes

Class 8 Fire Truck

-Pierce Volterra zero-
emissions pumper

City of Newark

Class 8 Refuse

N/A

-------
Fleet

EVs Deployed
/ Ordered

Vehicles
Delivered

Vehicle Type

Vehicle Model

City of Ocala

Class 6 Refuse

-BYD 6R

City of Paterson

Class 8 Refuse

N/A

City of Perth Amboy

Class 8 Refuse

N/A

City of Pittsburgh

Class 8 Bucket Truck
Class 3 Vans
Class 8 fire trucks

N/A

City of Trenton

Class 8 Refuse

N/A

City of Wilmington, NC

Class 8 Refuse

-Lion Electric

City of Woodland, CA

Yes

Class 4 Truck

-Pheonix Motorcars Zeus
500

Consolidated Edison of New
York

Class 8 Bucket Truck

-Custon built by Lion
Electric and Posi-Plus

Core-Mark International Inc.

Yes

Class 8 Tractor

-Freightliner eCascadia

Costco

Yes

Class 8 Tractor

-Freightliner eCascadia

County of Chautauqua

Yes

Yard Tractor

-Orange EV T-Series

Covenant Logistics

Class 8 Tractor

-10 Nikola Tre (BEVs)
- 40 Nikola Tre (FCV

DHE

Partially

Class 8 Tractor

-12 Volvo VNR Electric

DHL Worldwide Express

256

Partially

Class 8 Tractor
Class 3 Step Van
Class 3 Delivery Van

-100N/A Tesla Semi
-4 BYD 8TT
-63 Workhorse NGEN-1000
-100 Lightning Electric

Dickinson Fleet Services LLC

Class 6 Work Truck

-Xos Medium Duty

Dimension Fabricators

Yes

Terminal Tractor

-Orange EV T-Series

DocGo

Yes

Class 3 ambulance

-Ford Transit T350 Type II

Dole

Yes

Yard Tractor

-Orange EV

Donlen

100

Class 4

-Udelv Transporters

Dot Foods Inc./ Dot
Transportation

Yes

Terminal Tractor

-Orange EV T-Series

Eco-Cycle

Yes

Class 8 Refuse

-Mack LR Electric

EcoMaine

Class 8 Refuse

-Lion Refuse

Einride

200

Class 8 Tractor

-BYD 8TT

Elate Moving, LLC

Class 6 Box Truck

-N/A

Elizabeth Board of Education

Class 8 Refuse
Class 4 Delivery Trucks

-N/A

e Trucks

Class 3 Step Van

-Workhorse CI000

EV Semi-Fleet

Class 8 Tractor

-50 Tesla Semi
-1 Nikola Tre BEV

F&G, LLC

Yard Tractor

-NA

Fairfax County Department of
Public Works and
Environmental Services

Class 8 Refuse
Class 4 Van

-Workhorse CI000

Fastenal Co.

Yes

Class 6 Box Truck

-Freightliner eM2

-------
Fleet

EVs Deployed
/ Ordered

Vehicles
Delivered

Vehicle Type

Vehicle Model

FedEx Corp.

2,641

Partially

Class 3 Cargo Van
Class 8 Tractor
Class 4 Step Van
Class 4 Medium-duty
truck

-2500 GM Zevo 600 Cargo
Van

-20 Tesla semi trucks
-1 Workhorse Progen
concept Step Van
-120 XOS

Firefly Transportation
Services

Yes

Terminal Tractor

-T-Series Tandem

Fleetmaster Express Inc.

Partially

Class 8 Tractor

-12 Volvo VNR Electric
-2 Peterbilt Model 579EV
-2 Tesla Semis
-2 Dana Inc.

Fluid Truck

Yes

Class 4 Box Truck

- Lightning Electric

Forest River, Inc.

150

Class 4 Cutaway

-EV Star Cab and Chassis

Frito-Lay North America

Partially

Class 6 Box Truck
Terminal Tractor
Class 2b Van

-6 Peterbilt 220ev

-3 BYD 8Y
-41 Ford E-Transit

GATR Truck Centers

1,150

Class 5 Box Truck

-SEA Hino M5

Glovis America

Class 8 Tractor

-Hyundai XCIENT

Goodwill Industries
International

Yes

Class 6 Box Truck

- BYD T7

Green Mountain Power Corp.

Class 8 Bucket Truck

-Lion8 Bucket Truck

GSC Logistics

Yes

Class 8 Tractor

-BYD 8TT

Harbor Freight Transportation
Corp

Y ard tractor

N/A

Heniff Transportation Systems
Inc.

100

Class 8 Tractor

-Nikola Tre

Heritage Environmental
Services, LLC

100

Class 8 Tractor
Class 6 Box Truck

-80 Lion8
-20 Lion6

Hub Group

Yes

Class 8 Tractor

-Freightliner eCascadia

Hudson County Motors Inc

Class 8 Tractor

N/A

IKEA Distribution Services
North America

Yes

Terminal Tractor

- Kalmar's Ottawa T2
terminal tractor

Intelligent Labor and Moving

Yes

Class 6 Box Truck

-SEA Electric

International Motor Freight

Y ard tractors
Class 8 Tractor

N/A

Iron Mountain Information
Management Inc.

Yes

Class 6 Box Truck

-Freightliner eM2

J.B. Hunt

Partially

Class 8 Tractor
Class 6 Box Truck
Class 4 Box Truck

- 1 Navistar Fuel Cell Truck
-1 Freightliner eCascadia

-1 Freightliner eM2

- 5 Mitsubishi Fuso eCanter

J&M Sanitation

Yes

Class 8 Refuse

-BYD 8R

-------
Fleet

EVs Deployed
/ Ordered

Vehicles
Delivered

Vehicle Type

Vehicle Model

Jackson Township School
District

Class 8 Refuse

N/A

Jersey City

Class 8 Refuse

-BYD 8R

Karat Packaging

Class 8 Tractor

-Tesla Semi

KeHE Distributors

Yes

Class 8 Tractor

-Freightliner eCascadia

King County

Yes

Class 8 Tractor

-Kenworth T680E

Kingbee Rentals

Class 4 Cargo Van

-Envirotech Vehicles

Knight-Swift Transportation
Holdings

Yes

Class 8 Tractor

-Freightliner eCascadia

Kraft Heinz Company

Yes

Terminal Tractor

-Orange EV T-Series

L&R Group

Class 4 Shuttle Bus

-Pheonix Motorcars Zeus
400

Lazer Spot Inc.

Yard Tractor

-Orange EV

Lemcor Solid Waste Transfer
Station

Yard Tractor

N/A

Liberty Ashes, Inc

Class 6 Refuse

-1 Battle One Severe Duty
Refuse
-1 Battle One Crew Cab

Manhattan Beer Distributors
LLC

Class 8 Tractor

-Volvo VNR Electric truck

McLane Co Inc.

Yes

Terminal Tractor
Class 8 Tractor

-Orange EV Terminal Truck
-XOS HDXT

MDB Transportation

Class 6 Box Truck

-Kenworth K270E

Meijer

Class 8 Tractor

- Tesla Semi

Merchants Fleet

18,010

Partially

Class 3 Cargo Van
Class 2b Cargo Van
Class 5 Step Van

-12600 GMZevo 600
-5,400 GM Zevo 400
-10 XOS stepvan

Mesa Fire and Medical
Department

Class 8 Fire engine

-E-ONE Vector fire truck

Mondelez International Inc.

Yes

Class 8 Tractor

-Freightliner eCascadia

Municipality of Anchorage
Department of Solid Waste
Services

Yes

Class 8 Tractor

-Peterbilt Model 220EV and
Model 520EV

Murphy Road Recycling, LLC

Yard Tractor

-N/A

National Grid Service Co and
Operating Companies

TBA

Class 2b Van

-TBA Ford E-Transit

New LegendInc

Class 8 Tractor

-Freightliner eCascadia

Airgas

Class 8 Tractors

-Hyzon Fuel Cell

New York City Department of
Sanitation

Yes

Class 8 Refuse

-Mack LR Electric

-------
Fleet

EVs Deployed
/ Ordered

Vehicles
Delivered

Vehicle Type

Vehicle Model

NFI Transportation

117

Yes

Class 8 Tractor
Yard Tractor

-30 Freightliner eCascadia
-27 Kalmar Ottawa Electric
T2E Terminal Tractors
-60 Volvo VNR

Pacific Gas & Electric
(PG&E)

Class 4 Step Van

-MT50e

Pan-O-Gold Baking Co.

-N/A

Patton Logistics Group

Class 8 Tractor

-Volvo VNR

Penske Logistics

814

Partially

Class 8 Tractor
Class 6 Box Truck
Class 4 Box Truck
Class 2b van
Yard Tractor

-10 Freightliner eCascadia
-10 Freightliner eM2
-21 Freightliner
eCascadia/eM2
-4 Fuso eCanter
-2 ROUSH Ford F650
-5 Navistar International
eMV trucks
-751 Ford E-Transit
-TBA

PepsiCo Inc.

149

Partially

Class 8 Tractor
Class 6 Box Truck
Terminal Tractor
Class 2b vans

-100 Tesla semi trucks
- 40 Ford E-Transit

Performance Team

126

Class 8 Tractor

-Volvo VNR Electric

PGT Trucking Inc.

100

Class 8 Tractor

-Nikola Tre

Phil Haupt Electric

Yes

Class 4 Utility Truck

-ZEUS 500 Electric Utility
Truck

Pitt Ohio Transportation
Group

Yes

Class 4 Box Trucks

Class 8 Tractors
Class 7 Box Trucks

-N/A
-N/A

-Vovo VNR Electric

Port of Oakland

Yes

Class 4 Utility Truck
Class 8 Tractor

-2 Pheonix Motorcars Zeus
500

-10 Peterbilt Model 579EV
- 30 XCIENT Fuel Cell
heavy-duty tractors

Port of San Diego

Class 3 trucks
Class 3 vans

-N/A
-N/A

Pride Group Enterprises

6,570

Partially

Class 8 Tractor
Class 3 Step Van
Class 6 Box Trucks
Class 8 Box trucks

-150 Tesla Semi
-6320 Workhorse C-1000
-100 Lion6 and Lion8 trucks

Pritchard Auto Company

500

Class 3 Step Van

-Workhorse C-1000

Producers Dairy Foods Inc.

Yes

Class 8 Tractor

-Volvo VNR

Purolator

Yes

Class 6 Delivery Van

-Cummins Step Van

Quality Custom Distribution

Yes

Class 8 Tractor

-Volvo VNR Electric

Rail Management Services

Yes

Yard Tractor

-Orange EV T-Series

Ramsey/Washington
Recycling & Energy

Yes

Yard Tractor

-Orange EV T-Series

-------
Fleet

EVs Deployed
/ Ordered

Vehicles
Delivered

Vehicle Type

Vehicle Model

Recology

Yes

Class 8 Refuse

-BYD 8R

Red Hook Terminals LLC

Yes

Yard tractors

-BYD 8Y

Regional Industries LLC

Class 8 Refuse

N/A

Republic National
Distributing Company

Class 7 Tractor

-XOS MDXT

Republic Services Inc.

Yes

Class 8 Refuse

-Mack LR Electric

Reyes Holdings and Operating
Companies

Class 8 Tractor

-Tesla Semi

Ruan

Partially

Terminal Tractor
Class 8 Tractor

-3 Orange EVs
-5 Tesla semi trucks

Ryder System, Inc.

Partially

Class 5 Cargo Van
Class 6 Box Truck
Class 8 Tractor

-1 Freightliner eM2
-1 Freightliner eCascadia
-4 N/A

Sacramento County

Yes

Class 8 Refuse

-ElecTruck

Sacramento Municipal Utility
District

Yes

Class 3 Work Truck

-Zeus Electric Work Truck

Saia Inc.

103

Yes

Class 8 Tractor
Class 6 Box Truck

-2 VNR Electric trucks
-1 Freightliner eM2
-100 Nikola Tre

Santa Barbara Public Library

Yes

Class 4 Step Van

-Ford F-450 Retrofit

Schneider National Inc.

Yes

Class 8 Tractor

-Freightliner eCascadia

Shippers Transport Express
Inc.

Class 8 Tractor

-Peterbilt Model 579EV

Sonwil Distribution Center, In

Yes

Yard Tractor

-Orange EV T-Series

Southern California Edison
Co.

Yes

Class 8 Tractor

-Freightliner eCascadia

Southern Counties Express

Yes

Class 8 Tractor

-Toyota (Kenworth) T680E

Staples Inc.

Yes

Class 5 Box Truck

-SEA Hino 195 EV

Stolt Trucking, Inc.

-N/A

Sunbelt Rentals Inc.

Yes

Class 8 Tractor

-Peterbilt Model 579EV

Super Store Industries

Yes

Yard Tractor

-Orange EV T-Series

Sysco and Operating
Companies

851

Partially

Class 8 Tractor

-50 Tesla semi trucks
-801 Freightliner eCascadia

Tacoma Harbor

Yard Tractor

-N/A

Temco Logistics

Yes

Class 6 Box Truck

-Freightliner eM2

Terminal Consolidation Co

Yes

Terminal Tractor

-Orange EV T-Series

The Kroger Co.

Class 8 Tractor

-Tesla semi trucks

The Los Angeles City Fire
Department

Yes

Class 8 Fire engine

-Rosenbauer RTX Fire
Truck

Titan Freight

Class 8 Tractor

-Freightliner eCascadia

Toms River Township

Class 8 Refuse

N/A

-------
Fleet

EVs Deployed
/ Ordered

Vehicles
Delivered

Vehicle Type

Vehicle Model

Total Transportation Services

104

Partially

Class 8 Tractor
Class 8 Dray age

-2 Toyota (Kenworth)
T680E
-100 Nikola Tre
-1 Transpower Fuel Cell
-1 U.S. Hybrids Fuel Cell

Town of Cary

Class 8 Refuse

-N/A

Town of North Stonington

Class 8 Refuse

-N/A

Town of West New York

Class 8 Garbage trucks
Class 4 Shuttle buses

N/A

Township of Woodbridge

Class 8 Refuse
Class 4 Shuttle buses

N/A

Two Men and a Truck
Columbus

Class 6 Box Truck

-SEA Electric Conversion

UniFirst Corp.

Yes

Class 5 step van

-Xos Medium Duty

UPS Inc.

12,635

Partially

Class 8 Tractor
Class 6 Delivery Van
Class 6 Box Truck
Class 4 Step Van Retrofit
Class 4 Step Van
Class 4 Cargo Van
Class 3 Step Van

-4 Fuel Cell Electric Vehicle
Delivery Van
-3 Toyota (Kenworth)

T680E
-N/A Xos Medium Duty
-1000 Workhorse CI000
-125 Tesla Semi
-10000 Arrival Van
-2 Fuso eCanter
-1 Freightliner eCascadia
- 1500 Unique Electric
Solutions

US Foods

Yes

Class 8 Tractor
Class 6 Box Truck

-Freightliner eCascadia
-Freightliner eM2

USA Truck Inc.

Class 8 Tractor

-10 Nikola Tre

USPS

10,034

Yes

Class 3 Step Van
Class 4 Step Van

-8 Cummins
-7 Motiv E-450
-10,019 Oshkosh Defense
Next Generation Delivery
Vehicle

Valley Malt

Yes

Class 2b

-Ford E-Transit

Velocity Truck Rental &
Leasing

Yes

Class 8 Tractor

-Freightliner eCascadia

Wakefern Food Corp.

Terminal Tractor

N/A

Walmart Inc.

6,110

Class 3 Cargo Van
Class 2b Van

-5000 GM Zevo 400 and
Zevo 600 Cargo Van
-1110 Ford E-Transit

Waste Connections and
Operating Companies

yes

Class 8 Refuse

-Lion 8R

Waste Resource Technology,
Inc.

Yes

Class 8 Refuse

-BYD 8R

Watsontown Trucking
Company

Class 8 Tractor

-Volvo VNR

WattEV

Class 8 Tractor

-Volvo VNR

-------
Fleet

EVs Deployed
/ Ordered

Vehicles
Delivered

Vehicle Type

Vehicle Model

Werner Enterprises

Yes

Class 8 Tractor

-Peterbilt 579EV

XPO Logistics

102

Partially

Class 8 Tractor
Class 6 Box Truck
Class 4 Box Truck

-1 Freightliner eCascadia

-1 Freightliner eM2
-100 City Freighter CF1

Yellow Corp. (YRC Freight)

Yes

Terminal Tractor

-Orange EV

Estes

Class 8 Tractor

-Freightliner eCascadia

XL Fleet

Yes

Class 6 Refuse Truck

-Curbtender

Giant

Yes

Class 5 Step Van

-Motiv F-59

Xcel Energy

Class 8 Bucket Truck

-Terex Optima 55

Oatly

Class 8 Tractor

-Einride AB

Paterson Fire Department

Class 6 Ambulance

-Demers eFX Prototype
Ambulances

RoadOne

Yes

Class 8 Tractor

-Nikola Tre

United Rental

Class 2b Cargo Van

-Ford E-Transit

GE Appliance

N/A

Sunburst Truck Lines

Yes

Class 8 Dray age

-Nikola

Zeem Solutions

Class 5 Stepvan

-XOS Stepvan

City of Mobile

Class 8 Refuse

-Mack LR Electric

City of Gilbert

Class 8 Fire Truck

-Pierce Manufacturing
Volterra

Altec

Yes

Class 8 Bucket Truck

-Navistar eMV

Michigan State University

Class 2b

-Ford e-Transit

Wegmans

Yard Tractor

-N/A

Beyond Meat

Class 8 Tractor

-Einride AB

1.5.5.2 BEV Components Manufacturers

A small number of HD ICE vehicle component suppliers and startups have developed
components specifically for HD BEVs. See Table 1-19 for a partial list of manufacturers of HD
BEV components.

Table 1-19 Manufacturers of HD BEV Components

Component

Manufacturers

Low Voltage Battery

Same manufacturers as for ICE vehicles™1

Charge Port

ITT Cannon, Pheonix Contact, TE Connectivity

DC/DC Converter

Borg Warner, Eaton, EG Tronics, InMotion

Traction Motor

BAE, Borg Warner, Cummins, Dana, Lightning Systems, Meritor, Proterra,
SEA Drive, Siemens, ZF

Onboard Charger

Borg Warner, Dana, Eaton

Power Electronics Controller

Borg Warner, EG Tronics

Thermal System

Same manufacturers as for ICE vehicles™11

Traction Battery Pack

Borg Warner, CATL, Cummins, Dana, LG Chem, Panasonic, Proterra,
Samsung SDI, Tesla, Volvo, XALT

XX1 Manufacturers of Low Voltage Batteries includes Alliance and East Penn

xxu Manufacturers of Thermal Systems includes American Radiator, AP Air Inc, and CoolStar

-------
Transmission

Eaton

Aux System - Air Conditioner
Compressor

Guchen, Rheinmetal

Aux System - Heater

Guchen, Rheinmetal, Webasto

Aux System - Blower

Same manufacturers as for ICE vehicles™11

Aux System - Power Steering
Pump

Allied Motion, Bosch, HydraPulse, ZF

Aux System - Air Compressor

Hydrovane, Ingersoll Rand, Wabco

Auxiliary Power Unit (APU)

Carrier, Go Green APU, Phillips & Temro, Thermo King

1.5.6 BEV Research and Development

DOE has a Vehicle Technologies Office focused on research, development, and
demonstration of electrification technologies across sectors, including transportation. Through
the 21st Century Truck Partnership, DOE is collaborating with truck manufacturers, major
suppliers, and interagency partners to focus on removing barriers to wide-scale truck
electrification. They are working directly with industry through SuperTruck 3 to reduce
emissions of freight transportation, with the projects listed in Table 1-20 DOE Funded BEV
Projects Awarded in 2022awarded for 2022 through 2026 focused on HD BEVs.293

Table 1-20 DOE Funded BEV Projects Awarded in 2022294

Company

Project Description

Award Amount*

PACCAR Inc

Develop eighteen Class-8 battery electric and fuel cell vehicles
with advanced batteries and a megawatt charging station will also
be developed and demonstrated.

$32,971,041

General Motors, LLC

Develop and demonstrate four hydrogen fuel cell and four
battery electric Class 4-6 trucks. The project will also focus on
development of clean hydrogen via electrolysis and clean power
for fast charging

$26,061,726

* Subject to appropriations.

1.6 BEV Charging Infrastructure

1.6.1 Overview of BEV Charging Infrastructure

The work performed by heavy-duty vehicles has been described in Chapter 1.5 of this
document. HD BEVs require electricity for charging their batteries before work can be
performed, and it is critical that this be delivered at the appropriate time, rate, and location such
that business or other operational needs are met. This section provides an overview of BEV
charging infrastructure today; upcoming infrastructure investments; and considerations,
challenges and costs associated with future infrastructure needs for HD BEVs.

1.6.1.1 Definitions

In this section, we briefly summarize how we refer to various key terms in this proposed rule.
Electrical grid infrastructure includes power generation, transmission, and distribution systems
that provide electricity to charge BEVs along with many other users such as homes, businesses,
agriculture, and industry.

xxm Manufacturers of Aux System - Blower includes Four Seasons, Mahle, TYC, UAC, and Valeo

-------
BEV charging infrastructure consists of the equipment (and software) used to charge an
electric vehicle. In this draft RIA, we generally use the following terminology to describe
charging infrastructure, which is consistent with DOE's Alternative Fuels Data Center.295 When
citing external studies that use different terms, we do our best to interpret and map them
accurately. A station is the physical location where charging occurs. A station may have multiple
EVSE ports that provide electricity to a vehicle.XX1V The number of vehicles that can
simultaneously charge at the station is equal to the number of EVSE ports. Each port may also
have multiple connectors or plugs, e.g., to accommodate vehicles that use different connector
types, but each port can charge just one vehicle at a time. The relationship between a station,
EVSE ports, and connectors is shown in Figure 1-9.296

One Station

EVSE Port - equipment that can charge one vehicle
Connectors - may have one or more per port

Figure 1-9 Example charging station with four EVSE ports and six connectors

1.6.1.2 Types of EVSE Ports and Connectors

EVSE ports vary by power type and power level. There are two power types: alternating
current (AC) charging, where AC-to-direct current (DC) conversion takes place on-board the
vehicle, and DC fast charging (DCFC), where AC-to-DC conversion takes place prior to entering
the vehicle. Both AC charging and DCFC are further delineated by different power outputs,
though generally DCFC offers higher power and therefore faster charging times. Common AC
charging types are Level 1 (e.g., 1.9 kilowatt (kW)) and Level 2 (up to 19.2 kW),297 though there
is also a standard for higher-powered AC charging.298 DCFC is available today in a wide range
of power levels (e.g., 50-350 kW). While most vehicles use a standard connector for Level 1 and
2 charging (SAE J1772), there are multiple connectors for DCFC, including Combined Charging

xxw EVSE ports may be part of a wall-mounted unit or on a pedestal in the ground.

-------
System (CCS) and CHAdeMO, and the Tesla connector.xxv>299 OEMs producing HD BEVs may
also use proprietary connectors.300

How much time it takes a vehicle to charge will vary significantly based on the power level of
the EVSE port and the amount of electricity (kWh) needed, among other factors. For example,
using a 19.2 kW-rated Level 2 port, it will take longer than three hours to add 60 kWhxxvl, which
we assessed as the amount of electricity that would be sufficient for many Class 4-5 Step Vans
on most days. By contrast, it may take under one-and-a-half hours using DCFC-50 kW and just
under 30 minutes with DCFC-150 kW. In this example, Level 2 charging would be sufficient
provided the vehicle has the necessary three or more hours of dwell time off-shift, between
shifts, or while loading to charge. Otherwise, DCFC may be needed. (See also further discussion
regarding dwell times for charging in Chapter 2.6.4.1). Level 1 charging in this same example
could take over 30 hours, illustrating that Level 1 may not be practical for HD BEV applications.
For this reason, we focus the remainder of our infrastructure discussion and analysis on Level 2
and DCFC ports.

A standard for even higher-powered DCFC, the Megawatt Charging System (MCS), is
currently under development and being advanced by the National Renewable Energy Laboratory
(NREL), the Charging Interface Initiative (CharIN), and others.301 The MCS standard (expected
in 2024) has a potential charge rate of 3.75 MW.302 In a demonstration last year, a Scania truck
charging with Alpitronic equipment using this concept received power at over 1 MW.303 At the
same conference, ABB, a company that supplies charging infrastructure for LD and HD vehicles,
presented a new charger with up to 3 MW of power that could be available in 2024.304 In the
U.S., Daimler Truck North America and Portland General Electric have announced plans for
providing megawatt-level charging at the "Electric Island" station near Daimler's North
American headquarters.305

Other charging methods that could become more common in the future include wireless and
pantograph charging. Wireless charging (covered by the SAE J2954/2 standard306) simply
requires pulling the vehicle into place above a charging pad, and power is transferred via
induction to charge the battery.307 For pantograph charging systems (covered by the SAE
J3105/2 standard308), structures on top of the HD vehicle roof connect to overhead charging. HD
BEVs may be able to charge via pantograph while parked overnight or at critical locations on
their routes.309 Since these pantograph systems can supply power en-route, the truck battery can
potentially be downsized, allowing space and weight for additional cargo. Prototype systems
exist in Europe and development is underway by Siemens Mobility, Continental Engineering
Services, Webasto, and RWTH Aachen University.310'311

1.6.1.3 Types of Charging Stations

While charging stations may be deployed in a wide variety of locations and configurations
based on future needs, for our purposes, we broadly categorize charging stations as either depot
or en-route charging stations. Depot stations may be at warehouses, yards, distribution centers,
secure lots, or other locations where the vehicles are parked off shift. HD vehicles with return-to-

xxv Tesla also uses its own connector for AC charging, though a J1772 adapter is available.

XXV1 Charging rate may also vary based on the state of charge of the battery, e.g., by slowing down when the battery
is nearly full. In these examples (intended to be illustrative), we assume charging occurs at or near the stated power
of the EVSE.

-------
base operations, where vehicles return to a centralized location to park overnight, may be
particularly well suited for depot charging. As described in Chapter 2.6, we anticipate that many
heavy-duty BEV owners will opt to purchase and install sufficient EVSE ports for depot
charging at or near the time of vehicle purchase to ensure operational needs are met. We expect
many depot stations to be privately owned or operated for fleets.

We define en-route stations as those that allow vehicles to charge during their shift or en route
to their next location. These may be a mix of public stations that any HD vehicle can access and
use—pending any size or weight restrictions, and availability of compatible connector types or
privately operated. Certain vehicles, such as long-haul trucks, may depend on these stations for a
significant fraction of their daily electricity needs. As such, en-route stations will need to be
spaced closely enough together such that the vehicles can travel from station to station without
running out of power accounting for factors that could increase energy consumption such as high
or low temperatures or wind.

Initial applications of HD BEVs may be most practical with depot stations that handle the
charging need for vehicles with return-to-base operations. These depot stations can be planned
and implemented by entities with known duty cycle requirements. As the industry grows, we
expect more public, en-route stations will be needed, as discussed more in Chapter 1.6.2.3 of this
document.

1.6.2 Status and Outlook of BEV Charging Infrastructure
1.6.2.1 How much charging infrastructure is in the U.S. today?

There has been a rapid growth in BEV charging infrastructure in recent years, from just under
27,000 stations in 2019 to over 53,000 stations at the end of 2022.312 DOE's Alternative Fuels
Data Center Station Locator provides counts of stations and EVSE ports sorted by charging type
and private versus public control. Table 1-21 and Table 1-22 show the breakdown in U.S.
stations and EVSE ports as of February 15, 2023, for Level 2 and DCFC charging.313

Table 1-21 U.S. Charging Station Count

Stations

Public

Private

Level 2

45,037

3,398

DCFC

6,895

118

Table 1-22 U.S. EVSE Port Count

Ports

Public

Private

Level 2

101,163

12,585

DCFC

28,805

319

These stations and ports are not delineated by LD versus HD application. While many HD
vehicles can charge with Level 2 and DCFC equipment, it is important to note that the stations
themselves may not be designed to accommodate large vehicles. For example, stations designed
for HD vehicles may require more space for ingress and egress, higher canopies or roofs that can
fit tall cargo boxes, and longer charging cords. Stations may also not be designed to commingle
passenger cars with trucks and buses. Notwithstanding those limitations, some stations designed

-------
for light-duty vehicles may be able to accommodate (or modified in the future to accommodate)
medium-duty or small heavy-duty vehicles and so we include discussion of them here. As
previously discussed, Level 1 ports are less likely to meet HD BEV needs, so they are not
included in these counts.

Among networks in the Station Locator, ChargePoint is the largest with about 50,000 EVSE
ports (mostly Level 2) at over 27,000 stations.314 The largest DCFC networks (by port count) are
Tesla, Electrify America, and EVgo respectively.315 As discussed in Chapter 1.6.1.2 of this
document, there is not a universal connector type for DCFC, so the number of stations and ports
that can serve a given vehicle are likely lower than what is shown in Tables 1-22 and 1-23. For
example, Tesla's network, which grew from 8 charging stations in 2013316 to about 6,000 U.S.
stations today (with over 28,000 DCFC and L2 ports),317 primarily serves Tesla vehicles.
However, Tesla recently announced that by the end of 2024, 7,500 or more existing and new
ports (including 3,500 DCFC) would be open to all electric vehicles.318

While the Station Locator does not report how many public charging stations may be able to
accommodate different classes of vehicles, NREL has started collecting information on which
classes of vehicles use the subset of private ports for fleet charging. Collecting information on
private ports is challenging and the data set is not complete. For the private port data that has
been collected as of the second calendar quarter of 2022,xxvu NREL reports that about 45% of the
private EVSE ports were used primarily for fleets.319 Figure 1-10 shows a breakdown of Level 2
and DCFC private fleet EVSE ports in the Station Locator by vehicle type.xxvlll xxlx NREL notes
that efforts are underway to increase data collection for private fleets including school buses,
transit buses, and other fleets serving MD and HD vehicles.

6000

¦2 5000
o

w 4000

+g 3000
0)

(D 2000

4-»

ro
>

£ 1000
0

97%

— 67°/oM 33%

I Level 2 ¦ DCFC

xxvu Among the private ports in the Station Locator, NREL was able to collect information on fleet use and vehicle
classes for 88% of ports.

xxvl" Multiple vehicle types (e.g., LD, MD, or HD) may use the same EVSE stations or ports. Categorizations in the
chart reflect the largest class of vehicle that can use a given station.

XXLX Lhe NREL report also includes private fleet Level 1 EVSE ports. We did not include these in the figure.

-------
Figure 1-10 Private Fleet Level 2 and DCFC Ports by Fleet Type (Data Source: Alternative Fuels Data Center
Station Locator, Second Quarter 2022, from NREL report320)

We also note that there are a variety of charging stations for heavy-duty vehicles that are
planned or in development, as discussed in the following section, and these would not yet be
reflected in the Station Locator.

1.6.2.2 Who is installing charging infrastructure?

While dedicated HD charging infrastructure may be limited today, we expect it to expand
significantly over the next decade. The U.S. government is making large investments in charging
infrastructure through the BIL321 and the IRA,322 as discussed in Chapter 1.3.2 of this document.
This includes extending and modifying a tax credit that could cover up to 30% of the costs for
procuring and installing certain charging infrastructure (subject to a $100,000 per item cap) and
billions of dollars in funding programs that could support charging infrastructure either on its
own or alongside the purchase of a HD BEV. Private investments will also play a critical role in
meeting future infrastructure needs. Much of this will likely be charging infrastructure purchased
by individual BEV or fleet owners for depot charging. (See Chapter 2.6 of this document for
information on our analysis of depot charging needs and costs.) However, automakers, charging
network providers, energy companies and others are also investing in public or other stations that
could support en-route charging. This includes over a billion dollars for recently announced
projects to support electric truck or other commercial vehicle charging in the U.S. and Europe.323

For example, Daimler Truck North America is involved in an initiative in the U.S. with
electric power generation company NextEra Energy Resources and BlackRock Renewable
Power to collectively invest $650 million create a nationwide charging network for commercial
electric vehicles.324 They plan to start network construction in 2023 and by 2026 cover key
routes on the East and West Coast and in Texas with a later stage of the project also supporting
hydrogen fueling stations. Volvo Group and Pilot recently announced their intent to offer public
charging for medium- and heavy-duty BEVs at over 750 Pilot and Flying J North American
truck stops and travel plazas.325 In Europe, Volvo Trucks, Volkswagen's Traton (commercial
vehicle) Group, and Daimler Truck have joined forces to support HD vehicle charging. They
plan to build and operate 1,700 or more charging ports along major corridors and close to
logistics hubs.326 Tesla is developing charging equipment for their semi-trucks that will recharge
up to 70 percent of the Tesla semi-truck's 500-mile range in 30 minutes.327

Other investments will support regional or local travel needs. For example, Forum Mobility
announced a $400 million investment for 1,000 or more DCFCs for BEV trucks that are planned
for operation at the San Pedro and Oakland ports.xxx328 Logistics and supply chain corporation
NFI Industries is partnering with Electrify America to install 34 DCFC ports (150 kW and
350kW) to support their BEV drayagexxxl fleet that will service the ports of LA and Long Beach.
With funding from California, Volvo is partnering with Shell Recharge Solutions and others to

^ As noted by the Joint Office of Energy and Transportation in a summary of recent private sector investments in
charging infrastructure.

xxxl Dray age trucks typically transport containers or goods a short distance from ports to distribution centers, rail
facilities, or other nearby locations.

-------
deploy five publicly accessible charging stations by 2023 that will serve medium- and heavy-
duty BEVs in southern California between ports and industrial centers.329

A variety of solutions are being offered for, or explored by, fleets. For example, WattEV is
planning a network of public charging depots connecting ports to warehouses and distribution
centers as part of its "Truck-as-a-Service" model, in which customers pay a per mile rate for use
of, and charging for, a HD electric truck.330 The first station under construction in Bakersfield,
CA331 is planned to have integrated solar and eventually be capable of charging 200 trucks each
day; additional stations are under development in San Bernardino and near the Port of Long
Beach.330 Zeem Solutions also offers charging to fleets along with a lease for one of its medium-
or heavy-duty BEVs (via its "Transportation-as-a-Service" model). Zeem's first depot station
opened last year in the Los Angeles area and will support the charging of vans, trucks, airport
shuttles, and tour buses (among other vehicles) with its 77 DCFC ports and 53 L2 ports.332 Some
companies are starting with mobile charging units while they test or pilot vehicles.™1 For
example, Paccar has partnered with Heliox to offer 40 kW and 50 kW mobile charging units to
its dealers and customers of the Kenworth and Peterbilt brands333and Sysco, which plans to
deploy 800 Class 8 tractors in the next few years, plans to use mobile charging units to begin
their truck deployments while 14 charging stations are being installed.334 Nikola has partnered
with ChargePoint to provide fleet customers with a suite of options for charging infrastructure
and software (e.g., for charge management).335 AMPLY Power, which was acquired by BP in
2021, provides charging equipment and services for a variety of fleets, including van, truck, and
bus fleets.336

These recent heavy-duty charging announcements come during a period of rapid growth in the
broader market for charging infrastructure serving passenger cars and other electric vehicles.
BloombergNEF estimates that annual global investment was $62 billion in 2022, nearly twice
that of the prior year.337 Private charging companies have already attracted billions globally in
venture capital and mergers and acquisitions.338 In the U.S., there was $200 million or more in
mergers and acquisition activity in 2022 according to the capital market data provider
Pitchbook,339 indicating strong interest in the future of the charging industry. Domestic
manufacturing capacity is also increasing with over $600 million in announced investments to
support the production of charging equipment and components at existing or new U.S. facilities.

340, 341

States and utilities are also engaged. Seventeen states plus the District of Columbia (and the
Canadian province Quebec) developed a "Multi-State Medium- and Heavy-Duty Zero-Emission
Vehicle Action Plan," which includes recommendations for planning for, and deploying,
charging infrastructure.342 California is investing $2.9 billion through 2026 in BEV charging and
hydrogen fueling infrastructure (and related projects), including $1.7 billion specific to
infrastructure for medium- and heavy-duty vehicle applications.343 The Edison Electric Institute
estimates that electric companies are investing about $4 billion to advance charging
infrastructure and fleets.344 The National Electric Highway Coalition, a group that includes more
than 60 electric companies and cooperatives that serve customers in 48 states and D.C.345 aims to

xxxn Mobile charging units are EVSE that can move to different locations to charge vehicles. Depending on the unit's
specifications and site, mobile charging units may be able to utilize a facility's existing infrastructure (e.g., 240 V
wall outlets) to recharge. Mobile charging units may have wheels for easy transport.

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provide fast charging along major highways in their service areas. Other utilities, like the
Jacksonville Electric Authority (JEA) are supporting infrastructure through commercial
electrification rebates. JEA is offering rebates of up to $30,000 for DCFC stations and up to
$5,200 for Level 2 stations.346 Out west, Nevada Energy is supporting fleets by offering rebates
for up to 75% of the project costs for Level 2 ports and up to 50% of the project costs for DCFC
stations (subject to caps and restrictions).™11'347

1.6.2.3 Future Infrastructure Needs and Costs

We expect the many public and private investments described in Chapters 1.3.2 and 1.6.2.2
above to significantly expand BEV charging infrastructure for HD vehicles over the next decade.
However, more infrastructure will likely be needed as BEV adoption grows. In Chapter 2.6 of
this document, we describe how we accounted for charging infrastructure needs and costs
associated with the HD BEV penetration levels in this proposal. In this section, we discuss a few
recent assessments of charging infrastructure needs under different BEV penetration scenarios
from the literature. Estimates vary among the studies based on differing assumptions about the
population and mix of BEVs, charging types and power levels, among other factors.

For example, a recent International Council on Clean Transportation (ICCT) study that looked
only at tractor-trailers estimated that about 127,000 public and private charging ports would be
needed by 2030 to support approximately 100,000 zero-emission vehicles.XXX1V>348 Cumulatively
from 2021 to 2030, ICCT estimates this would require a $12 billion investment for charging
equipment and installation,xxxv about evenly split between publicly accessible infrastructure and
private depots.XXXV1>349 An Atlas analysis that looked at Class 3 to 8 trucks estimated that
commitments of between $100 and $166 billion in cumulative infrastructure investments would
be needed by the end of 2030 to support a 2030 fleet of over 1 million BEVs and start to build
infrastructure for future years.xxxv" This includes over $30 billion for about 500,000 depot
charging ports, with most of the remaining investment supporting on-road charging. Atlas notes
that the number of charging ports needed could vary widely based on the power level of charging
equipment, e.g., for long-haul trucking, up to 93,000 350-kW DCFC ports or up to 19,000 2-MW
DCFC ports may be needed to support the 2030 fleet.350

A study by the Goldman School of Public Policy at the University of California at Berkeley
evaluated a scenario in which 100 percent of new MD vehicle and HD truck sales are BEVs by
2035, requiring about 85,000 charging ports for MD vehicles (Class 2b-7) and 300,000 charging
ports for HD (Class 7-8 tractors) through 2035. A mix of 50-, 125-, and 300-kW DCFC ports
was assumed to support medium-duty trucks, mainly located at depots and warehouses, at a cost
of about $390 million annually through 2035. For heavy-duty trucks, the study assumed a mix of
125-, 350-, and 1000-kW DCFC ports located at approximately 2,700 truck stops at a cost of
about $3.6 billion annually through 20 3 5.351

xxxm Level 2 rebates are applicable to fleets with between 2 and 10 ports, and subject to a $5,000/port cap. DCFC

rebates are limited to 5 stations and are capped to the lesser of $400/kW or $40,000 per station.

xxxlv The study includes both battery electric and fuel cell electric vehicles.

xxxv This estimate also includes investment needed for 220 hydrogen refueling stations by 2030.

xxxvii 2030 investment totals include funding to start the buildout of infrastructure that Atlas projects will be
needed to support higher numbers of long-haul BEVs in 2035 (given lead time considerations such as permitting and
utility upgrades).

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The upfront capital investments needed to procure and install BEV charging infrastructure
will likely be borne by a combination of fleet owners (or others) deploying depot charging, and
public and private entities deploying en-route charging. (See Chapter 2.6.2 of this document for
information on hardware and installation costs per EVSE port.) As discussed in Chapter 1.3.2,
we expect some upfront capital costs for charging infrastructure to be offset by the tax credit in
the IRA where applicable.

Beyond upfront costs, BEV owners will generally be responsible for the cost of electricity to
charge. That charging cost can vary based on the applicable retail electricity rate, demand
charges, and other factors. As noted in a report by the National Association of Regulatory Utility
Commissioners, many utilities offer rates to incentivize charging at off-peak times such as time
of use rates or real-time pricing.352 Some utilities are also piloting approaches to reduce demand
charges for BEV fleet customers or station providers, e.g., by suspending them or offering
alternatives during initial years of operation.353'354 Since demand charges are typically assessed
based on the peak power (measured in kW) used in a billing cycle, they can be particularly
challenging for stations with multiple high-powered DCFCs. Demand charge rates vary widely
by utilityxxxvm and location, ranging from $0/kW (no demand charge) to over $50/kW according
to an NREL survey.355 The use of onsite battery storage, renewable generation, or managed
charging may help to lower peak demands at some stations and reduce these costs (as discussed
in Chapter 1.6.4 of this document). The price to charge at public stations may be higher than for
depot charging, as noted by a recent Atlas analysis, since the public charging price may
incorporate the profit margin of the third-party charging provider along with operating expenses,
and costs associated with charging equipment depreciation.356 Prices at public stations may also
vary in structure, e.g., costs may be assessed per kWh of electricity, per minute of charging, via a
monthly subscription fee, or another method with rates varying based on power level or other
factors. 357'XXX1X

1.6.3 Other BEV Charging Infrastructure Considerations

There are challenges and important considerations beyond costs when developing and
deploying charging infrastructure. These include interoperability, station design and siting
considerations, and the potential need for distribution system upgrades or other grid
considerations.

1.6.3.1 Interoperability

As discussed in Chapter 1.6.1, there is currently no universal standard for DCFC connectors,
which may limit the EVSE ports and stations a particular vehicle may use.xl This may pose a
challenge for public, en-route charging network providers trying to serve a wide range of
vehicles and for BEV drivers who may need to travel longer distances to find a station with the
right connector type. Depending on business requirements, fleets may also need to support
varying makes and models of HD BEVs that use different connectors,358 limiting the ability to
share and optimize the use of depot charging equipment. And once fleet owners have installed a

xxxvm In some cases, utilities may apply different demand charge rates ($/kW) based on whether a customer's
maximum power usage in a given billing cycle occurs on or off peak.

XXX1X In some states, there are prohibitions for entities other than utilities to sell electricity. Charging may be priced

by time or session instead of on a $/kWh basis.

xl Some EVSE ports are available with multiple connector types.

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particular connector type, it could limit their ability to buy new vehicles without incurring
additional EVSE costs. In some cases, adapters may be an option. For example, Tesla released a
CCS Combo 1 adapter in September of 2022 that would allow some of their cars to charge at
CCS ports installed by other providers.359 We also note movement toward standardized
connectors. For example, the National Electric Vehicle Standards and Requirements Final Rule
issued by the Federal Highway Administration in February 2023360 requires each DCFC port
funded under the NEVI Formula Program, or as part of a publicly-accessible EV charging
project under Title 23, U.S.C., to have a Combined Charging System (CCS) Type 1 connector.xh
Additionally, as discussed in Chapter 1.6.1.2, a non-proprietary standard for higher-power
charging, MCS, is currently in development.361

Physical connectors are only one aspect of interoperability. Communication protocols
between the network and chargers and between the charger and vehicle facilitate the flow of key
information important for charging and billing such as authentication, vehicle state of charge,
and power levels.362 The National Electric Vehicle Standards and Requirements Final Rule
requires the use of Open Charge Point Protocol for the former and ISO 15118 for the latter.363
The rule also requires the use of Open Charge Point Interface for communication between
charging networks.xl" Such requirements support standard communication for BEV charging—
advancing interoperability. We also note that the MCS incorporates ISO 15118.364 We intend to
monitor the movement toward standardized connectors and communication protocols as the HD
BEV market expands.

1.6.3.2 Station Design and Siting Considerations

How to best design and site depot charging stations will depend on fleets' vehicle mix,
operational needs, and site specifics. All sites need to have sufficient space for charging
equipment, with some stations potentially needing to accommodate onsite storage and generation
equipment as well.365 The canopy or roof height of the station and charging cords need to be
appropriately sized for the BEVs in the fleet and the station needs sufficient space for vehicle
ingress and egress. As discussed in Chapter 2.6.2, installation costs may be higher for sites with
longer distances between the charging equipment and electrical panel or where panel upgrades
are needed. Site ownership is another consideration. As noted in a report by the California
Energy Commission, installing charging equipment or making associated electrical upgrades
could depend on landlord-tenant relationships.366 In certain cases, responsibility for charging
infrastructure may be shared among different parties—potentially complicating planning and
upkeep. In addition to the above, siting and design for public or other en-route stations will need
to account for the operational needs, characteristics, and travel patterns of the different BEVs
they may support

The construction of any new charging station requires compliance with various building and
safety regulations.367 Permitting times can be a challenge and vary by region and site specifics.
For example, Electrify America reported that the permitting process took an average of 13 weeks
for its U.S. "ultra-fast" DCFC stations in 2021, but took over twice as long for stations in New
Jersey.368 Utility interconnection also adds time to the process. After site construction was
complete, Electrify America found an additional 12 weeks was required on average for
inspection, commissioning and other steps before a site was energized.368 Both permitting and

xh Additional non-proprietary connectors are allowed, provided each DCFC port has a CCS Type 1 connector.
xlu See rulemaking for required version numbers, implementation timeline and other details.

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utility interconnection times could be longer for larger, more complex, and/or higher-power
charging stations. For example, California's "Electric Vehicle Charging Station Permitting
Guidebook" notes that under a recent state law to help streamline the permitting process,
jurisdictions have twice as long (50 business days) to review and either approve or deny a permit
application for a site with 26 or more stations than one with 25 or fewer.369 Special permits, such
as a right of way permit or an encroachment permit may be required for stations that need a new
utility electrical service or for which trenching under a current right of way is needed
respectively—adding to the station deployment timeline. If upgrades to the electricity
distribution system are required, this could further extend the timeline (as discussed in Chapter
1.6.4 of this document below.)

1.6.4 Grid Considerations

How the additional electricity demand from BEVs will impact the grid will depend on the
time of day that charging occurs, the type or power level of charging, and the use of onsite
storage and vehicle-to-grid (V2G) or other vehicle-grid integration technology, among other
considerations. For example, depending on operational needs, BEVs may be able to be scheduled
to charge at off-peak hours when the electricity demand is easier to meet. As noted in a report by
the California Energy Commission, managed or smart charging could also enable increasing
renewable use if charging load is shifted to times with excess solar or wind that might otherwise
be curtailed.370 Charging at lower power levels (e.g., 50 kW rather than 350 kW) can reduce the
instantaneous power demand on the grid. Onsite battery storage, if deployed at charging stations,
could also reduce potential grid impacts by shifting when electricity is drawn from the grid while
still providing power to vehicles when needed. V2G technology, which allows electricity to be
drawn from vehicles when not in use, could even allow BEVs to enhance grid reliability.371 See
section II.V.2 of the Preamble for a discussion of grid reliability with respect to this proposal.

Planning for additional electricity demand is a standard practice for utilities and is not specific
to BEV charging. However, as discussed in Chapter 2.6.5.1, significant (and localized) increases
in load from charging stations could, in some cases, require upgrades to the electricity
distribution system. While these needs will be site specific, one recent study estimated that loads
of just 200 kW or higher could trigger the need for an onsite distribution transformer, which
could take three to eight months.372 New charging loads of several megawatts or higher—likely
only relevant for depots with many high-power DCFC unit ports—could require more significant
distribution system upgrades such as those to feeder circuits, breakers, or, in certain situations,
new substations. Such upgrades could take months to several years to implement.373 Planners for
transmission systems also need to account for BEV charging demand.374

There are a variety of approaches that could reduce the need or scale of such upgrades—
potentially saving both cost and deployment time. For example, distribution system capacity and
interconnection could be factored into the site selection process,375 and when possible, utilities
could work with station developers to evaluate multiple potential sites before a selection is
made.376 A recent report by the Interstate Renewable Energy Council identified such utility
coordination as an emerging best practice to help streamline station deployments. The report also
highlighted the potential value of utilities providing hosting capacity maps (HCMs) that identify
grid capacity constraints.377 As of mid-2022, requirements for HCMs or related analyses were in
place in ten states identified by Lawrence Berkeley National Laboratory.378 While the specific
requirements and contents of HCMs vary, where applicable, such maps could help station

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developers determine whether area feeders or substations have additional capacity for charging
or other loads. More broadly, 25 states and the District of Columbia have ongoing efforts and
requirements to support proactive distribution system planning and grid modernization.379

Other strategies could help station developers accommodate BEV charging demand for a
selected site. For example, automated load management or power control systems are being
explored as a way to dynamically limit total charging load and ensure it doesn't exceed available
capacity380—potentially reducing the need for some distribution upgrades. As noted above, the
use of onsite battery storage, managed charging, as well as onsite renewable generation may also
be able to reduce demand on the grid; some station operators may also opt for these technologies
to mitigate demand charges associated with peak power.381

Finally, we note that innovative or alternative charging options could reduce costs or
deployment time in some situations. For example, as discussed in Chapter 1.6.2, some companies
plan to use mobile charging units while stations are being deployed so BEVs can be incorporated
into the fleet without waiting for EVSE installation and utility interconnection. Mobile charging
units (and on-demand mobile charging services) are available at a variety of power levels and
configurations (e.g., the dual port Mobi EV charger by FreeWire Technologies provides AC
power up to 11 kW382 while Lightning eMotors offers units with five 80 kW DCFC ports.383)
Mobile charging units could also be a potential solution for locations in which it is challenging or
costly to make upgrades needed to install EVSE ports,384 as they can be recharged at locations
(and times) with sufficient capacity. Standalone charging canopies with integrated solar cells and
battery storage that don't need to be connected to the grid may be an option for remote or other
locations where it is costly or difficult to install EVSE.385

1.7 Fuel Cell Electric Vehicle Technology

Fuel cell technologies that run on hydrogen have been in existence for decades, though they
are just starting to enter the heavy-duty transportation market. Hydrogen fuel cell electric
vehicles (FCEVs) are similar to BEVs in that they have batteries and use an electric motor
instead of an internal combustion engine to power the wheels. Unlike BEVs that need to be
plugged in to recharge, FCEVs have fuel cell stacks that use a chemical reaction involving
hydrogen to generate electricity. Fuel cells with electric motors are two-to-three times more
efficient than ICEs that run on gasoline or diesel, requiring less energy to fuel.386

FCEVs do not emit air pollution at the tailpipe—only heat and pure water.387 With current and
near-future technologies, energy can be stored more densely onboard a vehicle as gaseous or
liquid hydrogen than it can as electrons in a battery. This allows FCEVs to perform periods of
service between fueling events that batteries currently cannot achieve without affecting vehicle
weight and limiting payload capacity. Thus, fuel cells are of interest for their potential use in HD
sectors that are difficult to electrify using batteries due to range or weight limitations.

The following sections discuss key technology components unique to heavy-duty FCEVs.
1.7.1 Fuel Cell Stack

A fuel cell system is composed of a fuel cell stack and "balance of plant" (BOP) components
that support the fuel cell stack (e.g., pumps, sensors, compressors, humidifiers). A fuel cell stack
is a module that may contain hundreds of fuel cell units, typically combined in series.388 A

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heavy-duty FCEV may have several fuel cell stacks to meet the power needs of a comparable
ICE vehicle.

Though there are many types of fuel cell technologies, polymer electrolyte membrane (PEM)
fuel cells are typically used in transportation applications because they offer high power density,
therefore have low weight and volume, and can operate at relatively low temperatures.389 PEM
fuel cells are built using membrane electrode assemblies (MEA) and supportive hardware. The
MEA includes the PEM electrolyte material, catalyst layers (anode and cathode), and gas
diffusion layers.390 Hydrogen fuel and oxygen enter the MEA and chemically react to generate
electricity, which is either used to propel the vehicle or stored in a battery to meet future power
needs. The process creates excess water vapor and heat.

Key BOP components include the air supply system that provides oxygen, the hydrogen
supply system, and the thermal management system. With the help of compressors and sensors,
these components monitor and regulate the pressure and flow of the gases supplied to the fuel
cell along with relative humidity and temperature. PEM fuel cells are highly sensitive to stack
operating conditions. These factors, if not properly controlled and optimized, can affect stack
voltage and the efficiency and performance of the system. Power consumed to operate BOP
components can also impact the stack's efficiency.391'392'393

Oxygen (O2) from the air enters the positive electrode (cathode) of the cell and hydrogen gas
(H2) enters the negative electrode (anode). A catalyst separates the hydrogen molecules in the
fuel into protons and electrons. The electrons create a direct flow of electricity. The protons flow
through the electrolyte membrane and create excess water vapor, which is purged along with any
contaminants. The electrochemical reaction also produced heat, which must be effectively
managed.394 To improve fuel cell performance, the air and hydrogen fuel that enter the system
may be compressed, humidified, and/or filtered.395 A fuel cell operates best when the air and the
hydrogen are free of contaminants, since contaminants can poison and damage the catalyst. PEM
fuel cells require hydrogen that is over 99 percent pure, which can add to the fuel production
cost.396 Hydrogen produced from natural gas tends to initially have more impurities (e.g., carbon
monoxide and ammonia, associated with the reforming of hydrocarbons) than hydrogen
produced from water through electrolysis.397 There are standards such as ISO 14687 that include
hydrogen fuel quality specifications for use in vehicles to minimize impurities.398

There are different strategies to mitigate excess heat that can reduce the cost of operating a
fuel cell. For example, a HD vehicle may include a cooling system the circulates cooling fluid
through the stack.399 Coolant temperatures needed to reject waste heat can impact efficiency. A
cooling system may be designed to accommodate end-of-life needs, which can be 1.5 to 2 times
greater than they are at the beginning of life.400 Waste heat recovery solutions are also

401

emerging.

Fuel cell durability, or the ability of the stack to maintain its performance over time, can be
negatively impacted by operating in less-than-optimized conditions. For example, prolonged
operation at high voltage (low power) or when there are multiple transitions between high and
low voltage can stress the system. As a fuel cell system ages, a fuel cell's MEA materials can
degrade, and performance and maximum power output can decline. The fuel cell can become
less efficient, which can cause it to generate more excess heat and consume more fuel.402

Fuel cell durability is important in heavy-duty applications, given that vehicle owners and
operators often have high expectations for drivetrain lifetimes in terms of years, hours, and
miles. DOE's ultimate long-term technology target for Class 8 HD trucks is a fuel cell lifetime of

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30,000 hours, corresponding to an expected vehicle lifetime of 1.2 million miles.403 A voltage
degradation of 10 percent at rated power by end-of-life is considered by DOE when evaluating
targets.403

Currently, the fuel cell stack is the most expensive component of a heavy-duty FCEV, due
primarily to the technological requirements of manufacturing rather than raw material costs.404
Larger production volumes are anticipated as global demand increases for fuel cell systems for
HD vehicles, which could improve economies of scale.404 Costs are also anticipated to decline as
durability improves, which could extend the life of fuel cells and reduce the need for parts
replacement.405 Fuel cells contain PEM catalysts that typically are made using precious metals
from the platinum group, which are expensive but efficient and can withstand conditions in a
cell. With today's technology, roughly 50 grams of platinum may be required for a 160-kW fuel
cell in a vehicle.406 Platinum group metals are classified as critical minerals in the DOE Critical
Minerals and Materials Strategy.407 Efforts are underway to minimize or eliminate the use of
platinum in catalysts.408

1.7.2 Fuel Cell and Battery Interaction

The instantaneous power required to move a FCEV can come from either the fuel cell stack,
the battery, or a combination of both. Interactions between the fuel cell stacks and batteries of a
FCEV can be complex and may vary based on application. Each manufacturer employs a unique
strategy to optimize the durability of these components and manage costs. The strategy selected
will impact the size of the fuel cell stack and the size of the battery.

The fuel cell stack can be used to charge the battery that in turn powers the wheels (series
hybrid or range-extending), or it can work with the battery to provide power (parallel hybrid or
primary power) to the wheels. In the emerging HD FCEV market, when used to extend range,
the fuel cell tends to have a lower peak power potential and may be sized to match the average
power needed during a typical use cycle, including steady highway driving. At idle, the fuel cell
may run at minimal power or turn off based on state of charge of the battery. The battery is used
during prolonged high-power operations such as grade climbing and is typically in charge-
sustaining mode, which means the average state of charge is maintained above a certain level
while driving. When providing primary power, the fuel cell tends to have a larger peak power
potential, sized to match all power needs of a typical duty cycle and to meet instantaneous power
needs. The battery is mainly used to capture energy from regenerative braking and to help with
acceleration and other transient power demands.409'410

Based on how the fuel cell stacks and batteries are managed, manufacturers may use different
types of batteries in HD FCEVs. Batteries with energy cells are typically used to store energy for
applications with distance needs, so may be used more with range-extending fuel cells in
vehicles. Batteries with power cells are typically used to provide additional high power for
applications with high power needs in primary power fuel cell-dominant vehicles.411

1.7.3 Onboard Hydrogen Storage Tanks

Fuel cell vehicles carry hydrogen fuel onboard using large tanks. Hydrogen has extremely low
density, so it must be compressed or liquified for use. There are various techniques for storing
hydrogen onboard a vehicle, depending on how much fuel is needed to meet range requirements.

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Most transportation applications today use Type IV tanks,xlm which typically include a plastic
liner wrapped with a composite material such as carbon fiber that can withstand high pressures
with minimal weight.412'413 High-strength carbon fiber is expensive, accounting for over 50% of
the cost of onboard storage at production volumes of over 100,000 tanks per year.414

Some existing fuel cell buses use compressed hydrogen gas at 350 bars (-5,000 pounds per
square inch, or psi) of pressure, but other applications are using tanks with increased compressed
hydrogen gas pressure at 700 bar (-10,000 psi) for extended driving range.415 A Heavy-Duty
Vehicle Industry Group was formed in 2019 to standardize 700 bar high-flow fueling hardware
components globally that meet fueling speed requirements (i.e. so that fill times are similar to
comparable HD ICE vehicles, as identified in DOE technical targets for Class 8 long-haul
tractor-trailers).416 High-flow refueling rates for heavy-duty vehicles of 60-80 kg hydrogen in
under 10 minutes were recently demonstrated in a DOE lab setting.xllv'417'418

Based on our review of the literature, we believe that most HD vehicles likely have sufficient
physical space to package hydrogen storage tanks onboard.419 Geometry and packaging
challenges may constrain the amount of gaseous hydrogen that can be stored onboard and, thus,
the maximum range of trucks that travel longer distances.420 Liquid hydrogen is emerging as a
cost-effective onboard storage option for long-haul operations. The technology readiness of
liquid storage and refueling technologies is still relatively low compared to compressed gas
technologies,421 so liquid tanks were not included as part of the technology package that supports
our proposed standards. Liquid hydrogen requires cryogenic storage at temperatures reaching -
253 degrees Celsius at atmospheric pressure. Preparing hydrogen for storage as a liquid is more
energy intensive than gaseous storage. For example, compression and cooling can require 10
kWh of energy per kg of hydrogen for liquid, compared to 3-5 kWh/kg of hydrogen for 700 bar
compressed hydrogen and 2 kWh/kg hydrogen for 350 bar.xlv'422 Nonetheless, companies like
Daimler and Hyzon are pursuing onboard liquid hydrogen to minimize potential payload impacts
and maintain the flexibility to drive up to 1,000 miles between refueling, comparable to today's
diesel ICE vehicle refueling ranges.423'424

Cryo-compressed hydrogen, a hybrid storage system option that combines compressed
hydrogen gas and liquid hydrogen, is under development but is even less ready for
commercialization than liquid hydrogen.415

1.7.4 Fuel Cell Electric Vehicle Safety Considerations

FCEVs have two potential risk factors that must be addressed through proper design, process,
and training: hydrogen and electricity. Electricity risks are identical to those of BEVs and, thus,
are discussed in Chapter 1.5.2. Hydrogen risks can occur throughout the process of fueling a
vehicle. Hydrogen must be safely delivered to a vehicle and then transferred into a vehicle's

xlm Type I-III tanks are not typically used in transportation for reasons related to low hydrogen density, metal
embrittlement, weight, or cost.

xllv DOE suggests that 60 kg of H2 will be required to achieve a 750-mile range in a Class 8 tractor-trailer truck,
assuming a fuel economy of 12.4 miles per kilogram. In the DOE lab, one filf (61.5 kg) was demonstrated from the

fueling station into seven type-IV tanks of a HD vehicle simulator, and the second fill (75.9 kg) was demonstrated

from the station into nine tanks.

xlv For reference, one kg of H2 includes 33.3 kWh of useable energy, which is about the same amount of energy as a
gallon of diesel. Fuel cell efficiency, which can exceed 60 percent (see Chapter 2), accounts for energy lost due to

friction when hydrogen is used in a FCEV.

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onboard storage tanks and fuel cell stacks. Hydrogen management is also required in the case of
an accident as structural damage and fire may cause hazardous conditions.

Hydrogen is flammable across a wide range of concentrations and can cause explosions if it is
not handled properly. If hydrogen escapes during a fueling operation or from a vehicle fueling
system, it can form a combustible mixture with air. The flammability range of hydrogen, 4% to
75%, is much greater than other common fuels.425 Hydrogen has a lower ignition energy than
gasoline vapor of 0.02 mJ compared to 0.24 mJ, so hydrogen will ignite more easily. Hydrogen
is colorless, odorless, and tasteless so detecting leaked hydrogen is difficult. Even when ignited,
the hydrogen flames are almost invisible so visually detecting a hydrogen fire is difficult and
flame detectors are highly recommended. Fortunately, hydrogen is light and quickly rises and
diffuses into the atmosphere to the point where it is no longer flammable, so flammable
concentrations are less likely to exist.

Components and systems that store and move hydrogen are designed to accommodate small
hydrogen molecules that are challenging to contain. Even with properly designed systems, small
leaks are common. The vehicles themselves may have minor leaks but must not leak hydrogen
into areas that can capture the rising gas. If vehicles are indoors for storage or repair, proper
passive ventilation must include outlet openings at the high point of the enclosure so the
hydrogen can vent. Active ventilation is also an option as fans and actuators exist that are
classified for use where hydrogen could be present. If a FCEV is outdoors under a roof, the roof
design must ensure that rising hydrogen does not have the opportunity to accumulate in any
traps.

Use of hydrogen in a FCEV drives design considerations and standard procedures that help
ensure safety during and after a crash. In-tank solenoid valvesxlvi are used to turn off hydrogen
flow if needed to prevent an uncontrolled release of hydrogen. The solenoid will close if a
prescribed level of impact is detected. First responders can help ensure solenoid closure by
turning the vehicle off or physically interrupting the 12V supply as the solenoid default (no
power) is off. If the physical integrity of the hydrogen storage tank is at risk due to fire, a
thermally activated pressure relief device (TPRD) will vent the hydrogen. FCEV designs protect
the hydrogen handling components. Since a crash may cause physical damage that releases
hydrogen, care is taken to avoid traps where hydrogen can accumulate. Training of first
responders for unique FCEV dangers and protocol is crucial. Vehicle specific emergency
response documentation that helps the first responders apply their training safely and efficiently
is also vital. Finally, post-crash, an initial inspection should be completed to verify the vehicle
can be safely removed from the crash site. The FCEV should then be stored in an isolated area
where final inspection and risk remediation can be implemented.426

Hydrogen has been handled, used, stored, and moved in industrial settings for more than 50
years, and there are established methods for doing so safely (e.g., see the Pacific Northwest
National Laboratory's Hydrogen Tools Portal).427 There is federal oversight and regulation
throughout the hydrogen supply chain system.428 Safety training and education are key for

xlvl A solenoid valve is a valve utilizing an electromagnet formed by a coil of wire in the shape of a cylinder. When it
carries a current, it acts like a magnet and the movable core is drawn into the coil causing the valve to either open or
close.

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maintaining reasonable risk while handling and using hydrogen. For example, hydrogen-related
fuel cell vehicle risks can be mitigated through:

• proper no/low leak designs for: infrastructure, hydrogen fill equipment, vehicle
connectors, and vehicle storage and supply;

• ambient hydrogen concentration monitoring and alarm;

• hydrogen pressure monitoring in the vehicle and infrastructure to indicate leaks;

• proper ventilation in and around hydrogen fueling equipment and fuel cell vehicles;

• vehicle controls to ensure the vehicle cannot be driven while fueling equipment is
attached; and

• vehicle controls that isolate hydrogen storage in the case of an accident.429
The following codes and standards are in place to guide safe use of hydrogen:

• SAE J2578, Recommended Practice for General Fuel Cell Vehicle Safety

• SAE J2579, Standard for Fuel Systems in Fuel Cell and Other Hydrogen Vehicles

• SAE J2990, Hybrid and EV First and Second Responder Recommended Practice (with
recommendations for hazards associated with hydrogen vehicles)

• OSHA standard 29 CFR 1910.103 on Hydrogen

As hydrogen demand increases, additional codes and standards at all levels of government are
likely going to be needed to accommodate heavy-duty FCEVs and fueling station development.

1.7.5 FCEV Market

The fuel cell market for heavy-duty vehicles is not as far along as the market for heavy-duty
BEVs. Models are still being developed and tested but are anticipated in the coming decade.
According to the Global Commercial Vehicle Drive to Zero Zero-Emission Technology
Inventory (ZETI), the following fuel cell vehicles are expected to become commercially
available for production in the United States and Canada region by CY 2024, as shown in Table
1-23.430

Table 1-23 Current and Projected North American HD Fuel Cell Vehicles

OEM

Vehicle

Class

Range

Est. Payload

Energy
Capacity

First
Available
Year

Hyundai

HDC-6 Neptune

Class 8

800 mi

2023

Hyzon

Class 8

500 mi

70 kg

2022

International

Class 8

500 mi

2024

Kenworth/T oy ota

T680

Class 8

150 mi

110,000 lbs

2023

Nikola

Tre

Class 8

500 mi

40,000 lbs

2023

Nikola

Two

Class 8

900 mi

40,000 lbs

2024

Toyota

Beta

Class 8

300 mi

88,184.9 lbs

40 kg

2023

Hyzon

Econic Refuse

Class 8

125 mi

2000 lbs

25 kg

2022

-------
Unique Electric
Solutions (UES)

FCCC MT-55FC

Class 6

140 mi

4000 lbs

2021

UES

F-59FC

Class 6

140 mi

4000 lbs

2021

UES

International 1652
FC

Class 6

150 mi

4000 lbs

2020

Hyzon

High-Foot Coach

Coach Bus

250 mi

35 kg

2021

ElDorado National

AXESSFC 35 ft

Transit Bus

260 mi

2020

ElDorado National

AXESS FC 40 ft

Transit Bus

260 mi

2020

New Flyer

Xcelsior CHARGE
H2 - 40 ft

Transit Bus

350 mi

37.5 kg

2020

New Flyer

Xcelsior CHARGE
H2 - 60 ft

Transit Bus

350 mi

60 kg

2020

According to the Hydrogen Fuel Cell Partnership, fuel cell electric buses have been in
commercial development for 20 years and, as of May 2020, over 100 buses are in operation or in
planning in the U.S.431 Foothill Transit in Los Angeles County ordered 33 fuel cell transit buses
that they expect to be operating in early 2023.432 There was successful testing of 10 Toyota-
Kenworth Class 8 fuel cell tractors in the Port of Los Angeles and surrounding area through
2022.433 Nikola has agreements with fleets to purchase or lease over 200 Class 8 trucks upon
satisfactory completion of demonstrations.434'435'436 They are building a manufacturing facility in
Coolidge, Arizona, with an expected production capacity of up to 20,000 BEV and FCEV trucks
by the end of 2023.437 Nikola's Tre FCEV received a certificate of compliance from the
California Air Resources Board (CARB), which brings it closer to eligibility as an authorized
vehicle under the Hybrid and Zero Emission Truck and Bus Voucher Incentives Project (HVIP)
program in California.438 Hyzon Motors has three Class 8 fuel cell truck options that qualify for
HVIP.439

Additional Class 8 fuel cell trucks are under development but may be for nonroad applications
such as yard tractors at ports or may not be available for production until after 2024. For
example, Hyundai Motor is launching the largest commercial deployment of fuel cell trucks in
the U.S. at the Port of Oakland in 2023, which some say positions them as a leader.440 Several
OEMs are partnering with companies in the hydrogen industry to advance truck technology and
infrastructure capabilities,441 including Hyundai, who has partnered with FirstElement for high
capacity mobile refuelers to support three of their Xcient truck pilots.442

Amazon and Walmart are among fleets owners and operators that are also considering
hydrogen. Amazon signed an agreement with Plug Power,443 a company building an end-to-end
hydrogen ecosystem, to supply hydrogen for up to 800 HD long-haul trucks or 30,000 forklifts
(which are commonly powered using hydrogen) starting in 2025 through 2040.444 Walmart is
purchasing hydrogen from Plug Power445 and plans to expand pilots of fuel cell forklifts, yard
trucks, and possibly HD long-haul trucks by 2040.446 Plug Power has agreed to purchase up to 75
Nikola Class 8 fuel cell trucks over the next three years in exchange for supplying the company
with hydrogen fuel.447

1.7.6 FCEV Component Manufacturers

Currently, most of the components of a fuel cell vehicle are the same as components in a HD
BEV. See Table 1-24 for an abbreviated list of manufacturers of HD FCEV-specific components
that are additional to a HD BEV.

-------
Table 1-24 FCEV Component Manufacturers

Component

Manufacturers

PEM Fuel Cell Stack448

Bosch, Ballard, Nuvera, Advent, Cummins, AVL, GM Hydrotec, Toyota

Hydrogen Tank449

Quantum, Hanwha Cimarron (Hanwha Solutions), Voith

This list includes Bosch, who announced an investment of $200 million in South Carolina to
produce fuel cell stacks for hydrogen fuel cell trucks,450 and General Motors, who announced
that it will supply fuel cells to Navistar.451 Toyota also announced plans to assemble fuel cell
modules for use in heavy-duty commercial trucks starting in 2023.452

1.7.7 FCEV Research and Development

DOE has a Hydrogen and Fuel Cell Technologies Office focused on research, development,
and demonstration of hydrogen and fuel cell technologies across sectors, including
transportation. As mentioned in Chapter 1.5.6 through the 21st Century Truck Partnership and
SuperTruck 3, they are working with industry stakeholders to reduce emissions of freight
transportation, with the projects listed in Table 1-25 for 2022 through 2026 focused on fuel cell
trucks.453

Table 1-25 DOE Funded Hydrogen HDV Projects Awarded in 2022454

Company

Project Description

Award Amount*

PACCAR Inc

Develop eighteen Class-8 battery electric and fuel cell vehicles
with advanced batteries and a megawatt charging station will also
be developed and demonstrated.

$32,971,041

Daimler Trucks North
America, LLC

Develop and demonstrate two 2 Class-8 fuel cell trucks with 600-
mile range, 25,000-hour durability, equivalent payload capacity
and range to diesel.

$25,791,669

Ford Motor Company

Develop and demonstrate five hydrogen fuel cell electric Class-6
Super Duty trucks targeting cost, payload, towing, and refueling
times that are equivalent to conventional gasoline trucks.

$24,952,314

General Motors, LLC

$26,061,726

* Subject to appropriations.

DOE also works with industry through the Million Mile Fuel Cell Truck (M2FCT) multi-lab
consortium to advance the efficiency and durability of PEM fuel cells at a pre-competitive level
to enable their commercialization for heavy-duty vehicle applications with an initial focus on
long-haul trucks.455

1.8 Overview of Hydrogen Industry and Infrastructure

Hydrogen produced from fossil fuels like natural gas has been a traded commodity for
decades. Approximately 10 million metric tons of hydrogen is produced annually in the United
States 456 Regional and national commitments to address climate change and energy security are
supporting the emergence of hydrogen from non-fossil sources. Recently adopted laws
containing tax incentives and policy frameworks (see Chapter 1.3.2) have taken over as the

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primary drivers of commercial growth in hydrogen production on the supply side. As the volume
of hydrogen production increases in response to these new incentives, costs of production are
expected to drop dramatically. On the demand side, the heightened awareness of climate change
has made many consumers and businesses increasingly interested in technologies with
decarbonization potential.

1.8.1 Hydrogen Characteristics and Use

Hydrogen is the lightest and most abundant element in the universe, composed of one proton
and one electron. It has low volumetric density, so it must be compressed or liquified for use, but
high gravimetric density, with about 2.5 to three times the energy content per unit of mass than
gasoline or diesel.45'

Today, hydrogen is mainly used in oil refining and other industrial sectors such as methanol
and steel production, and as a feedstock to produce chemicals like ammonia for products such as
fertilizer. As additional renewable electricity from wind and solar technologies is added to the
grid, hydrogen could be used as an energy carrier to seasonally store excess energy to help
balance intermittent supply with varying demand.4"18 Hydrogen could also be used as a fuel for
hard-to-decarbonize transportation modes like heavy-duty trucks, rail, and marine vessels. The
range of sectors that could participate in a larger H2 economy are demonstrated in Figure 1-11.4~9

Power
Generation

Hydrogen

Waste

h2° Hydrogen
Generation

Electric Grid
Infrastructure

Conventional Storage

Renewables

Nuclear

Fossil
with CCUS

Gas
Infrastructure

Transportation

t Synthetic
Fuels

Upgrading

m osi/

V mm./ Biomass

Ammo
Fertili;

Metals
Production

Chemical/Industrial
Processes

Heat/Distributed
Power

CCUS; Carbon Capture. Utilization, and SLorage

Figure 1-11 U.S. Department of Energy's 112 « Scale Concept
1.8.2 Low-GHG Hydrogen Production

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Low-GHG hydrogen production methods are at different levels of technology readiness and
range in cost and carbon emissions intensity.460 The following chart from DOE's "Pathways to
Commercial Liftoff report on Clean Hydrogen ("Liftoff Report") compares current well-to-
gatexlv" carbon intensities of several domestic pathways.

Comparison of domestic hydrogen production pathways

PTC value, $/kg $3.00 $1.00 $0.75 $0.50

Carbon intensity1, 2022 US

Production method kg C02e/kg H2 production

Reformation (SMR or ATR)
without CCS2

Reformation (SMR or ATR)
with >90% CCS3

Electrolysis (from grid <10/

electricity)5

10 15 25

-95%

<5%

Electrolysis (from renewables
and nuclear)4 I

Pyrolysis6 (L-U-

1 Excludes renewable natural gas feedstocks that would result in negative carbon intensities. Carbon Intensities shown are well-to-gale

2 Capex SMR facility capex (100k Nm3/h capacity); S215 million (current and 2030); reference case natural gas. S4.8/MMBtu (current). S3/MMBtu (2030); high case natural gas: $4.8/MMBtu (current).
$3.3/MMBtu (2030); high case based on EIA Advanced Energy Outlook 2022 high oil price scenario. Range for current reformation costs based on +/- 25% natural gas price.

3 Unit costs assumptions are the same as (1), plus CCS capex (for 100k Nm3 / h SMR facility): $145 million (current), $135 million (2030). Currently operational projects with CCS may have lower than 90%
capture rates. Negative values not shown but feasible with high percentages of RNG.

4 Assumes alkaline electrolyzer with installed capex: $1400/kW (current. 2MW electrolyzer, 450 Nm3/h), $425 / kW (2030, -90MW electrolyzer. 20,000 Nm3/h); reference case based on NREL ATB Class 5
onshore wind: capacity factor: 42% (current), 45% (2030), LCOE: $31/MWh (current), S22/MWh (2030): low case based on NREL ATB Class 1 onshore wind: capacity factor: 48% (current), 54% (2030), LCOE:
$27/MWh (current), 518/MWh (2030); high case based on NREL ATB Class 9 onshore wind: capacity factor: 27% (current). 30% (2030). LCOE: $48/MWh (current). S33/MWh (2030)

5 Electricity unit costs are based on median, top quartile, and bottom quartile 2030 grid LCOE by census region from EIA Annual Energy Outlook 2022; assumes the same electrolyzer installed capex as (5);
median LCOE: $68/MWh (current), $63/MWh (2030); top quartile LCOE: $66/MWh (current), $627MWh (2030); bottom quartile LCOE: $89/MWh (current), $80/MWh (2030); Grid carbon intensities are based on
data from the Carnegie Mellon Power Sector Carbon Index as well as national averages in grid mix carbon intensity - in some states, grid carbon intensity can be as high as 40 kg C02e I kg H2 (absent power
import / export across sate lines that can lower the carbon intensity of consumption, relative to generation)

6 Values with RNG not shown (which could include negative carbon intensities)

Sources: Hydrogen Council. NREL Annual Technology Baseline 2022, EIA Annual Energy Outlook 2022

Figure 1-12 DOE Comparison of Domestic Hydrogen Production Pathways461

This shows that today in the United States, over 95% of hydrogen is produced from natural
gas through a process called steam methane reforming (SMR). (Auto-thermal reforming, or
ATR, is a less prevalent gas reforming technology.) The methane in natural gas reacts with high-
temperature steam under pressure and in the presence of a catalyst to create hydrogen and carbon
monoxide (CO). The CO then reacts with steam to create carbon dioxide and more hydrogen.462
To reduce GHG impact, efforts are underway to test the potential of capturing the CO2 created
by SMR and either storing it underground or using it commercially. This potential strategy is

xiv» "Well-to-gate" is a system boundary used to evaluate lifecycle emissions from feedstock through to the point of
production.

-------
commonly referred to as carbon capture and storage (CCS).xlvm A concern with SMR and CCS is
methane leakage, since methane is a greenhouse gas that is more potent than CO2 at trapping
heat in the atmosphere. EPA has proposed rules to reduce methane from both new and existing
sources in the oil and natural gas industry that could help address this problem.463

Biomass gasification is a process that uses heat, steam, and oxygen to convert biomass to
hydrogen and other byproducts. Pyrolysis is the gasification of biomass without the use of
oxygen. Both can be used to produce hydrogen from methane generated from the decay of
biomass, which is an abundant renewable organic resource that can range from agricultural crop
or forest residues to organic municipal solid waste or animal waste. They do not involve
combustion but may require the use of a catalyst.464 Pyrolysis has other market dependences that
drive uncertainty, so is considered to have lower potential as a low-GHG pathway than SMR
with CCS and electrolysis.465

Electrolysis, which does not involve methane,xllx is the process of splitting water.

Electrolyzers are viable today. They function like fuel cells in reverse: fuel cells consume
hydrogen and oxygen to make electricity and water, while electrolyzers consume electricity and
water to make hydrogen and oxygen. When powered using the standard electricity grid, lifecycle
emissions can vary significantly by region across the country depending on the carbon intensity
of the grid. Over time as the grid decarbonizes, grid electrolysis can get cleaner. When powered
using renewable energy, electrolyzers emit virtually zero GHGs on a lifecycle emissions basis.466

Electrolysis is, however, energy intensive. DOE is investing in baseload energy resources
including nuclear reactors to scale low-GHG hydrogen production quickly and reduce
technology costs,467 and in hydropower dams that can also offer baseload energy for hydrogen
production.468'469 Electricity production at large existing reactors and dams is difficult to ramp up
and down. The desire to operate even when demand for electricity is low makes electricity
storage systems such as electrolytic hydrogen attractive as additive technologies for these large
generation assets in the near term. The potential for large-scale storage of excess hydrogen in
underground salt or lined hard rock caverns for later use when needed is an area of active
research.470 In the longer term, the need to balance electrical load across non-emitting generation
assets such as wind, solar, nuclear, and hydro will create additional opportunities for hydrogen
storage technologies.

1.8.2.1 Low- GHG Hydrogen Market

While many companies produce hydrogen for their own internal use, the list of companies
that produce and sell hydrogen in North America (i.e., "merchant" producers of hydrogen) is
much smaller. Four companies—Air Products, Praxair, Air Liquide, and Linde—produce a large
majority of the merchant hydrogen for North American markets. Their products are
predominantly produced via SMR. All four produce and sell gaseous hydrogen. Air Products and
Praxair produce the majority of merchant liquid hydrogen.471

xlvm When also discussing the possibility of using CO2 commercially, this strategy is referred to as carbon capture,
utilization, and storage (CCUS).

xllx The GHG intensities of hydrogen made using methane (SMR, ATR, and pyrolysis) also depend on the extent of
methane leaks during the production and transportation of the natural gas feedstock. Anticipated regulations and
advances in methane monitoring are expected to reduce these emissions and provide greater measurement certainty.

-------
As government and commercial support for both low-GHG hydrogen as a transportation fuel
and electrolytic hydrogen in general have grown in recent years, existing companies such as
Siemens and Cummins and new companies such as Plug Power and Nel Hydrogen have emerged
in this space to supply these products.472 These companies have diverse business models. Some
focus on production of hydrogen only, while others seek to become turnkey solutions for
companies looking to source hydrogen for vehicle use. Production strategies vary as well, with
some companies focusing on centralized production while others invest in onsite production
models. It is too early to tell whether growth in hydrogen supply and demand will lead to a
shifting landscape in the merchant hydrogen sector, or whether the established market players
will expand their portfolio to meet the need for low-GHG hydrogen as well.

1.8.2.2 Commercial Market Expansion

Chapter 1.3.2 includes a description of hydrogen provisions in BIL and IRA designed to
accelerate technology progress, reduce the cost of clean hydrogen production, and jumpstart the
hydrogen market in the United States. These programs aim to increase clean hydrogen
production from nearly zero today to 10 million metric tons (MMT) per year by 2030, 20 MMT
per year by 2040, and 50 MMT per year by 2050.473

DOE's draft Clean Hydrogen Strategy and Roadmap suggests a regional "clean hydrogen
hub" approach to infrastructure.474 Pursuant to funding provided by the BIL, as discussed in
Chapter 1.3.2.1, DOE is investing $8 billion through 2026 to support the development of atleast
four but up to 10 hubs that can demonstrate the production, processing, delivery, storage, and
end use of clean hydrogen. In their recent Funding Opportunity Announcement (FOA) associated
with this program, DOE stated that lifecycle GHG emissions will be a critical merit review
criterion for evaluating proposed hubs.475

Selected hubs will be expected to produce at a minimum rate of 50 metric tons per day and
some may reach 100 tons per day or more. These hub projects are opportunities to co-locate
clean hydrogen producers, who can leverage regional resources and feedstocks, with clean
hydrogen consumers from the industrial, power, transportation, and building sectors. These
coordinated and concentrated networks will be encouraged to take advantage of existing
infrastructure assets.476

The FOA requires projects to be executed over approximately 8 to 12 years (or faster),
depending on a hub's size and complexity. Applicants seeking funding are expected to propose a
four-phased project structure that includes detailed planning, development (including permitting
and financing), hub construction, plus two to four years of hydrogen production. The FOA
includes a list of the types of activities and materials required per phase to obtain funding (i.e.,
through a Go/No-Go decision process) for each phase of work.477

Subsequently and considering the impact of hub funding and tax credits under BIL and IRA,
including the hydrogen production tax credit (PTC), DOE released a Liftoff Report on clean
hydrogen to establish a common fact base moving forward for dialogue and coordinated action
across the full technology value chain (e.g., from upstream production to downstream end uses).
The report identifies three phases of rapid market growth: near-term expansion (-2023-2026),
industrial scaling (-2027-2034), and long-term growth (-2035+). The report acknowledges that
there are both opportunities and challenges for sectors with few decarbonization alternatives like
heavy-duty transportation end uses, including long-haul trucks.478

-------
During the timeframe of this rule (i.e., through 2032), the Liftoff Report lays out a scenario
where low-GHG hydrogen will be emerging for long-haul trucks:

1. Hydrogen will start getting cleaner:

1. By 2030, there is incentive to shift from producing 10 MMT per year of
hydrogen using SMR without CCS (<1 MMT per year of low-GHG hydrogen)
to producing 10 MMT per year of hydrogen using low-GHG pathways.

1. Industry expects electrolyzer costs to drop significantly by 2030,
though this is reliant on the availability of low-cost low-GHG
electricity that also needs to scale.

2. This shift can start with existing end users that already have hydrogen
infrastructure that connects production with end-use demand (e.g.,
industrial/chemicals).

3. New projects that receive hub funding are expected to break ground in the
near-term and advance new networks of shared infrastructure.

2. It will be challenging to establish regional infrastructure networks for end uses but
doing so can start to lower the delivered cost of hydrogen:

1. During industrial scaling, privately funded hydrogen infrastructure projects
will come online and start to build the midstream distribution and storage
networks to connect greater numbers of producers and offtakers.

2. Increasing production volumes will reduce costs that drive adoption of
hydrogen in new sectors like heavy-duty FCEVs.

3. Hydrogen will initially be dispersed through centralized regional hubs, and
then eventually through a more distributed network of infrastructure, followed
by anchors such as dedicated hydrogen pipelines and geologic storage in the
long term.

The proposed rule projects that hydrogen consumption from FCEVs will be a small
proportion of total hydrogen produced in 2020 (see Table 1-26), which means that it will require
a small proportion of the equivalent amount of total low-GHG hydrogen expected by 2030.
Furthermore, as noted earlier in this section, programs under BIL and IRA aim to increase clean
hydrogen production from 10 MMT per year by 2030 to 20 MMT per year by 2040. This
represents an average growth in clean hydrogen production of 1 MMT per year in the 2030s,
which far outpaces our projected growth of hydrogen consumption from FCEVs resulting from
this proposed rule.

Table 1-26 Excerpt from Table 6-1 in DRIA Chapter 6.5 on Estimated U.S. Oil Import Reductions and
Electricity Consumption Increases due to the Proposal *

Year

Hydrogen Consumption
(1000 metric tons per year)

% of 2020 U.S. Hydrogen Consumption

2030

130

1.3%

2031

440

4.4%

2032

830

8.3%

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*According to NREL in October 2020, US hydrogen demand is 10 million metric tons

annually.479

1.8.3 Hydrogen Transport and Distribution

Hydrogen can be transported and stored as a compressed gas or a cryogenic liquid. As a
pressurized gas, it can be delivered using pipelines or tube trailers. Higher volumes can be
delivered in liquid form using tanker trucks.480

Large-scale pipelines are not included in our assessment for this proposed rule. In the U.S.,
there is a network of about 1,600 miles of existing pipeline networks that are concentrated in
areas where hydrogen is currently produced and consumed, primarily in the Gulf Coast region.481
A dedicated hydrogen pipeline system for large-scale distribution will be more cost-effective in
the long term, as hydrogen volumes grow and provide economies of scale.482

To meet more immediate needs, end users generally can rely on hydrogen deliveries from
central production facilities. Hydrogen can be commercially delivered today in either gaseous or
liquid form. Tube trailers that carry compressed hydrogen gas contain long cylinders that are
stacked on a trailer, like those that carry compressed natural gas. They can carry up to 900 kg of
hydrogen per trailer.483 Travel distance may impact cost, but gaseous delivery requires less
capital than liquid delivery and can be cost-effective at smaller scales.484

Delivery using cryogenic liquid tanker trucks is more economical for longer distances and
higher volume demands, with the potential to carry roughly five times the amount of energy in a
comparable truck of gaseous hydrogen.485 Liquefaction requires about 30% more energy to cool
the hydrogen below -253 degrees Celsius (-423 degrees Fahrenheit) and can result in boil-off
during delivery, despite the quality of the insulation of the "dewar" or tank.486 Some studies
suggest that despite upfront capital costs and complexity associated with liquefaction, as the
technology matures, liquid H2 supply chains may prove to be cost-effective.487

Once onsite, hydrogen that is delivered may need to be conditioned for consumption in
vehicles using compressors, dispensers, chillers, and the like. It can be stored in bulk in tanks for
end use or seasonally stored in a gaseous or liquid form in above-ground vessels.488

An alternative to trucking hydrogen to a fueling station is to produce hydrogen onsite. This
can be costly but can offer a solution for locations that require larger volumes of hydrogen on a
regular basis. Consumers can purchase methane reformers or electrolyzers. Access to existing
natural resources and feedstocks such as natural gas and water at low cost, the carbon intensity
and cost of electricity, and other factors can be influential.489 Mobile fueling is another option,
where fuel providers can deliver a self-contained unit of product that can directly fuel a vehicle.
Mobile fueling may be more viable for remote locations or for operations that require limited
amounts of fuel.490

1.8.3.1 Midstream and Downstream Infrastructure

DOE's Liftoff Report notes that midstream infrastructure required to distribute and store
hydrogen beyond co-located production and offtake hubs, along with downstream infrastructure
(e.g., at hydrogen fueling stations for FCEVs), may not be feasible from a cost perspective in the
near-term. Through 2030, gaseous or liquid trucking is likely to be the primary method of
distributing hydrogen.

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Delivered hydrogen infrastructure is expected to become gradually more prevalent during the
2027-2034 "industrial scaling" phase of market development. The sunset of the hydrogen
production tax credit in 2032 will drive some buildout of midstream infrastructure for heavy-
duty transportation prior to 2032 in order to reduce costs so that infrastructure development can
extend beyond 2032. And as discussed in Chapter 1.3.2, the Alternative Fuel Refueling Property
Credit, which applies to hydrogen fueling stations, provides up to $100,000 per item in certain
census tracts when requirements are met. We expect that both provisions will help reduce costs
associated with refueling heavy-duty FCEVs through 2032.

Both midstream and downstream infrastructure beyond co-located facilities will require
investment and financing to address risk during an initial period of potentially low utilization, as
discussed in more detail in DOE's Liftoff Report. Heavy-duty fleet demand for hydrogen—
including in response to regulatory drivers—can improve the infrastructure network and catalyze
a "feedback loop" where more FCEV production and lower costs lead to more infrastructure
demand and lower infrastructure costs, which drive lower vehicle costs that then result in lower
infrastructure costs.491

1.8.4 Hydrogen Fueling Stations and Depots

The proposed rule considers a retail price of hydrogen, which is the total price of hydrogen
when it becomes available to the end user, including the costs of production, distribution,
storage, and dispensing at a fueling station, as described in more detail in DRIA Chapter 2.5.3.1.
This assumes that station capital costs are amortized within the price of per kilogram of
hydrogen. Consistent with the method we used for ICE vehicles, we did not account for stations
separately, nor did we distinguish between public or private fueling stations.

As is the case with battery electrification (see Chapter 1.6.1.3), fleets adopting fuel cell
technologies may opt for a private depot fueling model. Many of today's diesel fleet vehicles are
fueled at private depots and many fleets may prefer to maintain this model. However, we
considered FCEVs in the technology packages for select applications that travel longer distances
and/or carry heavier loads. This included coach buses, heavy-haul tractors, sleeper cab tractors,
and some day cab tractors. These vehicle applications would be less likely to return-to-base for
regular fueling and would likely need to use public en-route refueling on the way to their next
location.

As discussed in Chapter 1.8.2.1, government and private incentives may lead to new business
models for providing hydrogen to fleets. Some businesses offer turnkey solutions to fleets who
want hydrogen fueling at their depot but lack the expertise to site, build, and operate this
equipment. Other models focus on supplying hydrogen to fleets who are building their own
fueling operations. Others may offer innovative fueling solutions in non-traditional locations,
such as existing distribution centers that currently use hydrogen for nonroad applications (e.g.,
forklifts).1'492 This sector will grow and evolve over time.

Currently, DOE's Alternative Fuels Data Center (AFDC) lists 54 public retail hydrogen
fueling stations in the United States, primarily for light-duty vehicles in California. When
including private and planned stations in a search, there are over 130 refueling station locations
nationwide.493 There are also numerous nationally designated hydrogen-ready or hydrogen-

1 There are over 50,000 hydrogen-powered forklifts in the U.S. today.

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pending Alternative Fueling Corridors.494 Corridor-ready designations have public hydrogen
stations no greater than 100 miles apart and no greater than five miles off the highway. Corridor-
pending designations have public hydrogen stations separated by more than 100 miles but no
greater than five miles off the highway.495

A 2021 ICCT study evaluated infrastructure needed to support a 100% zero-emission tractor-
trailer fleet in the United States by 2040. Along with charging capacity for HD BEVs, they
projected roughly 200 hydrogen refueling stations by 2030 and close to 3,000 by 2040, growing
to around 7,000 stations by 2050. They assumed that hydrogen would meet the needs of vehicles
traveling over 650 miles per day. Stations would have the capacity to deliver over 4,800 kg per
day, with an assumed cost of $6 million per station based on 2020 estimates that would decline
as station use increases and with learning over time. With fewer HD FCEVs than HD BEVs on
the road, far fewer hydrogen fueling stations are required to meet demand compared to charging
stations in their analysis.496

The West Coast Collaborative's Alternative Fuel Infrastructure Corridor Coalition (WCC
AFICC) is actively considering buildout of a network for medium- and heavy-duty vehicles
throughout the western states.11'497 During their Phase 1 and 2 analyses, the WCC AFICC
received 153 project proposals for hydrogen stations out of 283 proposals for all fuel types
(including EV, LPG, CNG, and LNG).498 They estimate station throughputs of 3,000, 8,000, or
15,000 kg/day, with a capital cost of about $9 million, $24 million, or $45.5 million per station,
respectively.

1.8.5 Environmental Considerations

Recent investment and policy interest in hydrogen is rooted in its decarbonization potential.
As discussed above, the BIL requires development of a Clean Hydrogen Production Standard to
establish targets that limit lifecycle emissions of hydrogen production over time. The IRA clean
hydrogen production tax credit discussed in Chapter 1.3.2 offers larger incentives for hydrogen
produced using cleaner sources of energy. The focus of these programs is on reducing the
emissions and carbon intensity of hydrogen production.

Science about the potential of hydrogen to have indirect warming impacts is still being
evaluated. Hydrogen does not absorb and trap heat within the Earth's atmosphere and is
therefore not considered a direct greenhouse gas. The Intergovernmental Panel on Climate
Change (IPCC) and United Nations Framework Convention on Climate Change (UNFCCC)
have not identified and established a global warming potential1" associated with hydrogen.499
However, studies show that there are indirect radiative effects caused by the presence of emitted
hydrogen in the troposphere.500 Limited research suggests that hydrogen released to the
troposphere may affect ozone concentrations and prolong the lifetime of resident methane.501'502

Due to its extremely small molecular size, there can be leakage of gaseous hydrogen during
production, transportation, storage, and dispensing into vehicles. It may need to be vented or
purged when used in equipment. Such losses are expected to be small at this point in time, due to
the relatively small volumes of hydrogen in production today (e.g., 10 MMT produced per year
in the United States and 90 MMT per year globally, compared to up to 660 MMT of global low-

11 States in the WCC AFICC include Arizona, California, Idaho, Montana, Nevada, Oregon, Utah, and Washington.
111A Global Warming Potential (GWP) is a quantified measure of the globally averaged relative radiative forcing
impacts of a particular GHG relative to carbon dioxide.

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GHG hydrogen potential in 2050 to meet climate goals).503 Even as hydrogen scales and much
larger volumes are produced, with the attendant potential for emissions of hydrogen to oxidize in
the atmosphere, we expect the benefits of low-GHG hydrogen as part of a low-carbon economy
to outweigh any such effects in the future.504 Furthermore, there is financial incentive to improve
how to measure, monitor, evaluate, and manage hydrogen losses throughout the value
chain.505'506 Research is underway to understand ways to ensure that climate benefits of hydrogen
can be maximized and any potential adverse effects minimized.507

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126 Health and Safety Executive - Electric and Hybrid Vehicles https://www.hse.gov.uk/mvr/topics/electric-
hvbrid.htm Accessed February 2, 2023.

127 UES. "EV Conversions for Commercial Vehicles - UES". https://www.uesmfg.com/. Accessed on October 5,
2022.

128 Revo Powertrains. "Revo Electric Powertrains". https://www.revopowertrains.com/. Accessed on October 5,
2022.

129 Barclay, J. "Blue Bird to Offer Electric Repower Option for Gasoline- and Propane-Powered School Buses".
Business Wire. Published on August 3, 2022. https://www.businesswire.eom/news/home/20220803005655/en/Blue-
Bird-to-Offer-Electric-Repower-Option-for-Gasoline—and-Propane-Powered-School-Buses/. Accessed on October
5, 2022.

130 Complete Coach Works. "Zero Emission Propulsion System", https://zepsdrive.com/. Accessed on September 18,

2022.

131 Spartan Fire, LLC. "Vector - Spartan Emergency Response", https://spartaner.com/products/vector/. Accessed on
September 18, 2022.

132 Kenworth. "Kenworth Delivers Two Range-Extended Electric Prototype Trucks for Commercial Service".
Published on February 17, 2021. https://www.kenworth.com/about-us/news/kenworth-delivers-two-range-extended-
electric-prototype-trucks-for-commercial-service/. Accessed on October 5, 2022.

133 US Hybrid. "Long Haul & Drayage - US Hybrid", https://www.ushvbrid.com/applications/long-haul-dravage/.
Accessed on October 5, 2022.

134 Hyliion. "Hybrid - Hyliion". https://www.hvliion.com/hvbrid/. Accessed on October 5, 2022.

135 Pierce Manufacturing, Inc. "Volterra™ Electric Fire Truck | Pierce Mfg". http s: //www. piercemf g. com/electric -
fire-trucks/pierce-volterra. Accessed on January 8, 2023.

136 Bollinger Motors Inc. "TRUCKS - BOLLINGER MOTORS", https://bollingermotors.com/trucks/. Accessed on
September 18, 2022.

Bollinger Motors Inc. "CLASS 3-6 FLEET-READY ELECTRIC TRUCKS - BOLLINGER MOTORS".
https://bollingermotors.com/class-3-through-6-electric-truck-platforms/. Accessed on September 18, 2022.

137 Howard, B. "Volvo Plans Big Electric Trucks for Local, Regional Hauls". Extreme Tech. Published on
September 24, 2019. https://www.extremetech.com/extreme/298830-volvo-plans-big-electric-trucks-for-local-
regional-hauls. Accessed on October 5, 2022.

138 Peterbilt. "220EV". https://www.peterbilt.com/download/file/7696. Accessed on October 5, 2022.

139 Green Car Congress. "Navistar launches new medium-duty electric International eMV Series; in production and
available to order". Green Car Congress. Published on September 2, 2021.
https://www.greencarcongress.com/2021/09/202109Q2-emv.html. Accessed on October 5, 2022.

140 Xos. "Powertrain - Powered by Xos helps to electrify vehicles and equipment".
https://xostrucks.com/powertrain/. Accessed on October 5, 2022.

141 U.S. International Trade Commission. "Residential Heat Pump (Hybrid) Water Heater Market, Production, and
Trade". Executive Briefings on Trade, February 2022.

https://www.usitc.gov/publications/332/executive briefings/ebot residential heat pump hybrid water heaters.pdf.
Accessed January 24, 2023.

142 Hockenos, P. "In Europe's Clean Energy Transition, Industry Turns to Heat Pumps". Yale Environment 360.
Published January 19, 2023. https://e360.vale.edu/features/europe-industrial-heat-pumps. Accessed January 24,

2023.

143 Osaka, S. "Why you might want a heat pump in your electric car". Washington Post. Published on January 7,
2023. https://www.washingtonpost.com/climate-solutions/2023/01/Q7/electric-vehicles-cold-winter-range/.

Accessed January 24, 2023.

144 Garry, M. "C02 Heat Pumps Found to Outperform Electric Heaters in Electric Buses". R744. (ATMOsphere).
Published January 25, 2022. https://r744.com/co2-heat-pumps-found-to-outperform-electric-heaters-in-electric-
buses/. Accessed January 24, 2023.

145 U.S. Department of Energy. See www.energy.gov/sites/default/files/2022-02/bto-cchp-fact-sheet-021822.pdf

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146 Altec. "JEMS Electrifying your MD/HD Fleet". Available here https://www.altec.com/green-fleet-2/ Accessed
on 3/13/2023.

147 Odyne. "System Overview". Available here: http s: //www .odvne.com/sv stem -overview/. Accessed on 1/26/2023.

148 https://www.macktrucks.com/trucks/lr-electric/

149 ABC Companies. Vicinity Lightning LT28e. Available online: https://www.abc-companies.com/listings/2023-
vicinity-lightning-lt28e-10/

150 ARBOC Specialty Vehicles. Equess Charge. Available online: https://arbocsv.com/models/equess-
charge/#:~:text=Equess%20CHARGE%E2%84%A2%20is%20a,%C2%AE%20with%20no%20steps%20throughou
t!

151 Arrival. Van. Available online: https://arrival.com/us/en/topic/van

152 Autocar. E-ACTT. Available online: https://www.autocartruck.com/actt/eactt/

153 Battle Motors. LET. Available online: https://battlemotors.com/pages/lnt-ev

154 Battle Motors. LET 2. Available online: https://battlemotors.com/pages/let-ii-ev-specs

155 Blue ARC. EV. Available online: https://bluearcev.eom/#specifications

156 Blue Bird. All American Electric. Available online: https://www.blue-
bird.com/images/RE_Electric_Spec_Sheet_09_30_22.pdf

157 Blue Bird. Vision Electric. Available online: https://www.blue-bird.com/buses/vision/vision-electric-bus

158 Blue Bird Micro Bird. G5 Electric. Available online: https://www.microbird.com/g5-electric

159 Bolinger Motors. Deliver-e. Available online: https://uncrate.com/2022-bollinger-deliver-e-electric-van/

160 Bollinger Motors. B4 Chassis Cab. Available online: https://bollingermotors.com/trucks/

161 Brightdrop. EV600. Available online: https://www.gobrightdrop.com/products/brightdrop-zevo

162 BYD. 6F. Available online: https://en.byd.com/truck/class-6-truck/#:~:text=Cab%20%26%20Chassis-
,The%20BYD%206F%20is%20the%20world's%20first%20commercially%20available%20all,of%20performance%
2C%20endurance%20and%20reliability.

163 BYD. 6R. Available online: https://en.byd.com/truck/class-6-refuse-truck/

164 BYD. 8R. Available online: https://en.byd.com/truck/class-8-refuse-truck/

165 BYD. 8TT. Available online: https://en.byd.com/truck/class-8-day-cab/

166 BYD. 8Y. Available online: https://en.byd.com/truck/terminal-tractor/

167 BYD. C10M. Available online: https://en.byd.com/bus/bus-clOm/

168 BYD. C10MS. Available online: https://en.byd.com/bus/bus-clOms/

169 BYD. C6M. Available online: https://en.byd.com/bus/bus-c6m/

170 BYD. C8M. Available online: https://en.byd.com/bus/bus-c8m/

171 BYD. C8MS. Available online: https://en.byd.com/bus/bus-c8ms/

172 BYD. C9M. Available online: https://en.byd.com/bus/bus-c9m/

173 BYD. K11M. Available online: https://en.byd.com/bus/kl lm/

174 BYD. K7M. Available online: https://en.byd.com/bus/k7m/

175 BYD. K7MER. Available online: https://en.byd.com/bus/k7mer/

176 BYD. K8M. Available online: https://en.byd.com/bus/k8m/

177 BYD. K9M. Available online: https://en.byd.com/bus/k9m/

178 BYD. K9MD. Available online: https://en.byd.com/bus/k9md/

179 BYD. Type D Electric School Bus. Available online: https://en.byd.com/bus/school-bus/school-bus-d/

180 Canadian Electric Vehicle. Might-E Truck. Available online: https://canev.com/pages/might-e-truck

181 Canoo. MPDV. Available online: https://www.canoo.com/mpdv/

182 City Freighter. CF1. Available online: https://www.cityfreighter.com/

183 Complete Coach Works. ZEPS. Available online: http://www.completecoach.com/wp-
content/uploads/2013/07/ZEPS-Brochure.pdf

184 Dulevo. D.Zero2. Available online: https://www.dulevo.com/us/products/street-sweepers/dulevo-d-zero2/

185 El Dorado National. Axess Evo-BE. Available online: https://www.eldorado-ca.com/axess-evo-be

186 Envirotech Drive Systems. Logistics Van. Available online: https://evtvusa.com/vehicles/logistics-van/

187 Envirotech Drive systems. Cutaway Van. Available online: https://evtvusa.com/vehicles/cutaway-van/

188 Envirotech Drive Systems. Urban Truck. Available online: https://evtvusa.com/vehicles/urban-truck/

189 Ford. E-Transit Cargo Van. Available online: https://www.ford.com/commercial-trucks/e-transit/models/cargo-
van /

190 Freightliner. eCascadia. Available online: https://freightliner.eom/trucks/ecascadia/specifications/#tab-l

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191 Freightliner. eM2. Available online: https://freightliner.com/trucks/em2/specifications/

192 Freightliner Custom Chassis. eM2 Walk-in Van. Available online: https://www.electricwalkinvan.com/

193 Gillig. Battery Electric Bus. Available online: https://www.gillig.com/battery-electric

194 Global Environmental Products. M3EV. Available online: https://globalsweeper.com/products/mechanical/m3-
electric-100 -plug-in

195 Global Environmental Products. M4EV. Available online: https://globalsweeper.com/products/mechanical/m4-
electric-100 -plug-in

196 Greenpower Motor Company. Beast. Available online: https://greenpowermotor.com/wp-
content/uploads/Brochures/BEAST_Brochure.pdf

197 Greenpower Motor Company. AV Star. Available online: https://greenpowermotor.com/gp-products/av-star/

198 Greenpower Motor Company. EV Star Cargo. Available online: https://greenpowermotor.com/wp-
content/uploads/Brochures/EVSTARC_Brochure.pdf

199 Greenpower Motor Company. EV Star Cargo +. Available online: https://greenpowermotor.com/wp-
content/uploads/Brochures/EVSTARC+_Brochure.pdf

200 Greenpower Motor Company. EV Star CC. Available online: https://greenpowermotor.com/wp-
content/uploads/Brochures/EVSTARCC_Brochure.pdf

201 Greenpower Motor Company. EV Star. Available online: https://greenpowermotor.com/wp-
content/uploads/Brochures/EVSTAR_Brochure.pdf

202 Greenpower Motor Company. EV Star +. Available online: https://greenpowermotor.com/wp-
content/uploads/Brochures/EVSTAR+_Brochure.pdf

203 Greenpower Motor Company. EV250. Available online: https://greenpowermotor.com/wp-
content/uploads/Brochures/EV250_brochure.pdf

204 Greenpower Motor Company. EV350. Available online: https://greenpowermotor.com/wp-
content/uploads/Brochures/EV350_brochure.pdf

205 Greenpower Motor Company. EV550. Available online: https://greenpowermotor.com/gp-products/ev550-bus/

206 Greenpower Motor Company. Synapse 72. Available online: https://greenpowermotor.com/greenpowers-
synapse-72-school-bus-commences-demonstration-tour/

207 Greenpower Motor Company. Synapse Shuttle Bus. Available online: https://greenpowermotor.com/greenpower-
delivers-synapse-shuttle/

208 Hino. XL7. Available online: https://www.hino.com/assets/20201005-project-z_pr_final.pdf

209 Hometown Manufacturing. Villager. Available online: https://hometown-mfg.com/trolleys/villager

210 Hometown Manufacturing. Mainstreet. Available online: https://hometown-mfg.com/trolleys/mainstreet

211 Hometown Manufacturing. Streetcar. Available online: https://hometown-mfg.com/trolleys/streetcar

212 Hometown Manufacturing. View. Available online: https://hometown-mfg.com/buses/view

213 Hometown Manufacturing. Commuter. Available online: https://hometown-mfg.com/buses/commuter

214 Hometown Manufacturing. Urban. Available online: https://hometown-mfg.com/buses/low-floor-urban

215 Hyundai. Elec City. Available online: https://trucknbus.hyundai.com/global/en/products/bus/elec-city

216 IC Bus. CE Electric. Available online: https://www.icbus.com/-

/media/Project/Navistar/ICBus/ICBus/Electric/NA V22_IC_BUS_eCE_SpecSheet_2022_rd02.pdf

217 Avevai. Iona Van. Available online: https://avevai.com/products/iona-van/

218 Kalmar Ottawa. T2E+. Available online:

https://www.kalmarglobal.com/4946e2/globalassets/media/268794/268794_Kalmar-Ottawa-Electric-Terminal-
Tractor-T2E-_Brochure-web.pdf.pdf

219 Kenworth. K270e K370e. Available online: https://www.kenworth.com/trucks/k270e-k370e/

220 Kenworth. T680e. Available online: https://www.kenworth.com/trucks/t680e/

221 Lightning eMotors. City Transit Bus Repower. Available online: https://lightningemotors.com/buses/

222 Lightning eMotors. ZEV3 Transit Cargo Van. Available online: https://lightningemotors.com/zev3-transit-cargo-
van /

223 Lightning eMotors. ZEV4 Vox Truck. Available online: https://lightningemotors.com/lightningelectric-class4-
cutaway/

224 Lightning eMotors. ZEV4 Shuttle Bus. Available online: https://lightningemotors.com/lightningelectric-class4-
shuttle/

225 Lightning eMotors. ZEV4/ZEV5 Step Vans. Available online: https://lightningemotors.com/step-vans/

226 Lightning eMotors. ZEV5/ZEV6 Trucks. Available online: https://lightningemotors.com/zev5-zev6-trucks/

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227 Lion Electric. Lion6, Lion8, Lion8 Bucket, Lion8 Refuse ASL, Lion8 Refuse REL, Lion8T. Available online:
https://thelionelectric.com/documents/en/Lion8_all_applications.pdf

228 Lion Electric. LionA. Available online: https://thelionelectric.com/documents/en/onepager_LionA_EN.pdf

229 Lion Electric. LionC. Available online: https://thelionelectric.com/documents/en/BrochureLionCang.pdf

230 Lion Electric. LionD. Available online: https://thelionelectric.com/documents/en/liond_specs_en.pdf

231 Lion Electric. LionM. Available online: https://thelionelectric.com/documents/en/spec_LionM_EN_US.pdf

232 Mack Trucks. LR Electric. Available online: https://www.macktrucks.com/trucks/lr-electric/specs/

233 Mercedes Benz Bus. eCitaro. Available online: https://www.mercedes-benz-
bus.com/en_DE/models/ecitaro/technology.html

234 Mercedes Benz Trucks. eActros. Available online: https://www.mercedes-benz-
trucks.com/en_GB/emobility/world/our-offer/eactros-and-services.html

235 Mitsubishi Fuso. eCanter. Available online: https://www.mitsubishi-fuso.com/en/product/ecanter/

236 Motiv Power Systems. E-450. Available online: https://www.motivps.com/application/electric-box-truck/

237 Motiv Power Systems. F-59. Available online: https://www.motivps.com/application/electric-step-van/

238 Motor Coach Industries. Electric Series Specs. Available online: https://www.mcicoach.com/coach/electric-
series/specs/

239 International Trucks. eMV. Available online: https://www.internationaltrucks.com/trucks/emv-series/detailed-
specs

240 New Flyer. Xcelsior Charg NG. Available online: https://www.newflyer.com/bus/xcelsior-charge-ng/

241 Nikola. Tre BEV. Available online: https://nikolamotor.com/tre-bev

242 Nova Bus. LFSe. Available online: https://us.novabus.com/blog/bus/lfse/

243 Nova Bus. LFSe+. Available online: https://us.novabus.com/blog/bus/lfse-plus/

244 Optimal EV. SI. Available online: https://www.optimal-ev.com/sl

245 Optimal EV. El. Available online: https://www.optimal-ev.com/el

246 Orange EV. Electric Truck. Available online: https://orangeev.com/electric-trucks/

247 Peterbilt. Electric Vehicles. Available online: https://www.peterbilt.com/electric-vehicles

248 Phoenix Motorcars. Zeus 400, Zeus 500. Available online: https://www.phoenixmotorcars.com/wp-
content/uploads/2022/10/ZEUS-400-and-500-Flyer.pdf

249 Phoenix Motorcars. Zeus 600 School Bus. Available online: https://www.phoenixmotorcars.eom/products/#bus

250 Proterra. ZX5+ 35' Bus. Available online: https://www.proterra.com/wp-
content/uploads/2022/09/SPEC_3 5_001 _Q4_2022_V 1 _09_01 _22.pdf

251 Proterra. ZX5+ and ZX5 Max 40' Bus. Available online: https://www.proterra.com/wp-
content/uploads/2022/09/SPEC_40_001 _Q4_2022_V 1 _09_01 _22-1 .pdf

252 Rivian. Fleet. Available online: https://rivian.com/fleet

253 Roush CleanTech. F-650 Electric. Available online: https://www.roushcleantech.com/penske-roush-cleantech-
proterra-announce-f-650-electric-commercial-trucks/

254 Scania. NXT. Available online: https://www.scania.com/us/en/home/about-scania/innovation/scania-nxt.html

255 Sea Electric. Hino 195. Available online: https://www.sea-electric.com/products/195ev/

256 Sea Electric. Hino GH. Available online: https://www.sea-electric.com/products/gh-ev/

257 Sea Electric. Hino FM. Available online: https://www.sea-electric.com/products/fm-ev/

258 Sea Electric. Hino FG. Available online: https://www.sea-electric.com/products/fg-ev/

259 Sea Electric. Hino FE. Available online: https://www.sea-electric.com/products/fe-ev/

260 Sea Electric. Hino 917. Available online: https://www.sea-electric.com/products/sea-hino-917-ev-sea-drive-120a/

261 Sea Electric. Isuzu FRR. Available online: https://www.sea-electric.com/products/frr-ev/

262 Sea Electric. Isuzu FSD. Available online: https://www.sea-electric.com/products/fsd-ev/

263 Sea Electric. Isuzu FTR. Available online: https://www.sea-electric.com/products/ftr-ev/

264 Sea Electric. Isuzu NLR. Available online: https://www.sea-electric.com/products/nlr-ev/

265 Sea Electric. Isuzu NNR. Available online: https://www.sea-electric.com/nnr-ev-2/

266 Sea Electric. Isuzu NPR. Available online: https://www.sea-electric.com/products/npr-ev/

267 Sea Electric. Isuzu NRR. Available online: https://www.sea-electric.com/products/sea-isuzu-evs/nrr-ev/

268 Sea Electric. Ford F-59. Available online: https://www.sea-electric.com/products/f59-ev/

269 Sea Electric. Ford F-650 andF-750. Available online: https://www.sea-electric.com/products/f650-ev/

270 Sea Electric. Ford Transit. Available online: https://www.sea-electric.com/products/transit-ev/

271 Sea Electric. Sea 300-45. Available online: https://www.sea-electric.com/products/sea-300-45-ev/

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272 Sea Electric. Sea 500. Available online: https://www.sea-electric.com/products/sea-500-ev/

273 Sea Electric. SV6. Available online: https://www.sea-electric.com/products/sv6-ev-step-van/

274 Sea Electric. School Bus Type A. Available online: https://www.sea-electric.com/wp-
content/uploads/2022/06/SEA-Type-A-School-Bus-eBrochure-%E2%80%93-USA-Mar22.pdf

275 Sea Electric. School Bus Type C. Available online: https://www.sea-electric.com/wp-
content/uploads/2022/06/SEA-Type-C-School-Bus-eBrochure-%E2%80%93-USA-Mar22.pdf

276 Terraline Trucks. LH1. Available online: https://terralinetrucks.eom/#tangra-lhl

277 Terberg Special Vehicles. YT203-EV. Available online:

https://www.terbergspecialvehicles.eom/en/vehicles/terminal-tractors/#YT203-EV

278 Tesla. Semi. Available online: https://www.tesla.com/semi

279 Thomas Built Buses. Saf-T-Liner C2 Jouley. Available online: https://thomasbuiltbuses.com/school-buses/saf-t-
liner-c2-jouley/

280 US Hybrid. Transit. Available online: https://www.ushybrid.com/applications/transit/

281 Van Hool. CX45e. Available online: https://www.vanhool.com/en/vehicles/coaches/coaches-usa/cx45e

282 Van Hool. TDX25e Astromega. Available online: https://www.vanhool.com/en/vehicles/coaches/coaches-
usa/tdx25e-astromega-usa

283 Volvo. VNR Electric. Available online: https://www.volvotrucks.us/trucks/vnr-electric/

284 Volvo. 7900 Electric. Available online: https://www.volvobuses.eom/en/city-and-intercity/buses/volvo-7900-
electric/specifications.html

285 Workhorse Group. W750. Available online: https://workhorse.com/w750/

286 XL Fleet. Electric Refuse Truck. Available online: https://curbtender.com/curbtender-xlfleet-allelectric-hybrid/

287 XOS Trucks. Step Van. Available online: https://www.xostrucks.com/stepvan

288 XOS Trucks. HDXT. Available online: https://www.xostrucks.com/hdxt

289 XOS Trucks. MDXT. Available online: https://www.xostrucks.com/mdxt

290 Hexagon Purus. eM2. Available online: https://hexagonpurus.com/our-solutions/battery-and-fuel-cell

291 Zeus. Electric Vocational Trucks. Available online: https://zeuselectricchassis.com/electric-vocational-trucks/

292 Environmental Defense Fund. Electric Fleet Deployment & Commitment List. Available here:
https://docs.google.com/spreadsheets/d/110m2DolmiSemrb DT40YNGou4o2m2Ee-KLSvHC-
5vAc/edit#gid=204973 8669

293 U.S. Department of Energy. "DOE Projects Zero Emissions Medium- and Heavy-Duty Electric Trucks Will Be
Cheaper than Diesel-Powered Trucks by 2035". March 2022. Available online:

https://www.energv.gov/articles/doe-proiects-zero-emissions-medium-and-heaw-dutv-electric-trucks-will-be-
cheaper-diesel.

294 U.S. Department of Energy. "DOE Announces Nearly $200 Million to Reduce Emissions From Cars and Trucks.
November 1, 2021. Available online: https://www.energy.gov/articles/doe-announces-nearly-200-million-reduce-
emissions-cars-and-trucks.

295 U.S. Department of Energy. "Developing Infrastructure to Charge Electric Vehicles". Alternative Fuels Data
Center. Available online: https://afdc.energy.gov/fuels/electricitv infrastructure.html.

296 Ibid.

297 Ibid.

298 SAE. "SAE International Releases New Specification (SAE J3068) for Charging of Medium and Heavy Duty
Electric Vehicles". April 26, 2018. Available online: https://www.sae.org/news/press-room/2018/04/sae-
international-releases-new-specification-sae-i3068-for-charging-of-medium-and-heaw-dutv-electric-vehicles.

299 U.S. Department of Energy. "Developing Infrastructure to Charge Electric Vehicles". Alternative Fuels Data
Center. Available online: https://afdc.energy.gov/fuels/electricitv infrastructure.html.

300 Alexander, Matt et al. California Energy Commission. "Assembly Bill 2127 Electric Vehicle Charging
Infrastructure Assessment Analyzing Charging Needs to Support Zero-Emission Vehicles in 2030". Available
online: https://www.energv.ca.gov/programs-and-topics/programs/electric-vehicle-charging-infrastructure-
assessment-ab-2127.

301 National Renewable Energy Laboratory (NREL). "Industry Experts, Researchers Put Charging Systems for
Electric Trucks to the Test". August 30, 2021. Available online: https://www.nrel.gov/news/program/2021/industrv-
experts-researchers-put-charging-svstems-for-electric-trucks-to-test.html.

302 Kane, Mark. "CharIN Officially Launches The Megawatt Charging System (MCS)". Inside EVs. June 15, 2022.
Available online: https://insideevs.com/news/592360/megawatt-charging-svstem-mcs-launch/.

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303 Ibid.

304 Fisher, Ryan. "Electric Trucks Get Boost From Multi-Megawatt Charging Stations". Bloomberg U.S. Edition.
June 22, 2022. Available online: https://www.bloomberg.com/news/articles/2022-06-22/electric-trucks-get-boost-
from-multi-megawatt-charging-stations?leadSource=uverifv%20w all.

305 Kane, Mark. "Electric Island: See First Charging Site Designed For Big Trucks" INSIDEEVS. April 22, 2021.
Available online: https://insideevs.com/news/502793/electric-island-charging-site-trucks/.

306 SAE International. "Wireless Power Transfer for Heavy-Duty Electric Vehicles". December 16, 2022. Available
online: https://www.sae.Org/standards/content/i2954/2 202212/.

307 Oak Ridge National Laboratory. "Successful delivery: ORNL demonstrates bi-directional wireless charging on
hybrid UPS truck". April 21, 2020. Available online: https://www.ornl.gov/news/successful-deliverv-ornl-
demonstrates-bi-directional-wireless-charging-hvbrid-ups-truck.

308 SAE International. "Electric Vehicle Power Transfer System Using Conductive Automated Connection Devices
Vehicle-Mounted Pantograph (Bus-Up)". January 20, 2020. Available online:
https://www.sae.Org/standards/content/i3105/2 202001/.

309 Transport for London. "New rapid, wireless bus charging technology introduced as part of the capital's journey
to zero emission". October 26, 2022. Available online: https://tfl.gov.uk/info-for/media/press-
releases/2022/october/new-rapid-wireless-bus-charging-technologv-introduced-as-part-of-the-capital-s-iournev-to-
zero-emission.

310 Randall, Chris. "Continental & Siemens to cooperate on truck pantographs". ElectricDrive.com. July 29, 2021.
Available online: https://www.electrive.com/2021/07/29/continental-siemens-to-cooperate-on-truck-pantographs/.

311 Webasto. "E-Truck with pantograph: Webasto supports pioneering pilot project". August 29, 2022. Available
online: https://www.automotiveworld.com/news-releases/e-truck-with-pantograph-webasto-supports-pioneering-
pilot-project/.

312 U.S. Department of Energy. Electric Vehicle Charging Infrastructure Trends. Alternative Fuels Data Center.
Available online: https://afdc.energy.gov/fuels/electricitv infrastructure trends.html.

313U.S. Department of Energy. Alternative Fueling Station Locator. Alternative Fuels Data Center. Available online:
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314 Loveday, Steven. "A Comprehensive Guide to U.S. EV Charging Networks" U.S. News. January 4, 2023.
Available online: https://cars.usnews.com/cars-trucks/advice/ev-charging-stations.

315 Brown, Abby, Jeff Cappellucci, Emily White, Alexia Heinrich, and Emma Cost. 2022. "Electric Vehicle
Charging Infrastructure Trends from the Alternative Fueling Station Locator: Second Quarter 2022." Golden, CO:
National Renewable Energy Laboratory. NREL/TP-5400-84263. Available online:

http s: //www. nrel. go v/doc s/fv 23 o sti/8 ¦4263. pdf.

316 Shahan, Zachary. "Tesla Supercharger Network Evolution—From 6 to 1,533 Superchargers in 6 Years".
CleanTechnica. July 6, 2019. Available online: https://cleantechnica.eom/2019/07/06/tesla-supercharger-networks-
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317 U.S. Department of Energy. Alternative Fueling Station Locator. Alternative Fuels Data Center. Available
online:

https://afdc.energy.gov/stations/#/analyze?country=US&fuel=ELEC&access=private&access=public&ev_connector
s=TESLA.

318 Osaka, Shannon. "Elon Musk agrees to open parts of Tesla's charging network to everyone". The Washington
Post. February 15,2023. Available online: https://www.washingtonpost.com/climate-
environment/2023/02/15/tesla-supercharger-network-locked/

319Brown, Abby, Jeff Cappellucci, Emily White, Alexia Heinrich, and Emma Cost. "Electric Vehicle Charging
Infrastructure Trends from the Alternative Fueling Station Locator: Second Quarter 2022." Golden, CO: National
Renewable Energy Laboratory. NREL/TP-5400-84263. 2022. Available online:
https://www.nrel.gov/docs/fv23osti/84263.pdf.

320 Brown, Abby, Jeff Cappellucci, Emily White, Alexia Heinrich, and Emma Cost. "Electric Vehicle Charging
Infrastructure Trends from the Alternative Fueling Station Locator: Second Quarter 2022." Golden, CO: National
Renewable Energy Laboratory. NREL/TP-5400-84263. 2022. Available online:
https://www.nrel.gov/docs/fv23osti/84263.pdf

321 Infrastructure Investment and Jobs Act, Pub. L. No. 117-58, 135 Stat. 429 (2021). Available online:
httpsV/www.congress.gov/l 17/plaws/publ58/PLAW-l 17publ58.pdf.

-------
322 Inflation Reduction Act, Pub. L. No. 117-169, 136 Stat. 1818 (2022). Available online:
httpsV/www.congress.gov/l 17/plaws/publl69/PLAW-l 17publl69.pdf

323 BloombergNEF. "Zero-Emission Vehicles Factbook A BloombergNEF special report prepared for COP27."
November 2022. Accessed March 5, 2023. https://www.bloomberg.com/professional/download/2022-zero-
emissions-vehicle-factbook/.

324 NextEra Energy. News Release: "Daimler Truck North America, NextEra Energy Resources and BlackRock
Renewable Power Announce Plans to Accelerate Public Charging Infrastructure for Commercial Vehicles Across
The U.S." January 31, 2022. Accessible online: https://newsroom.nexteraenergy.com/news-releases?item=123840.

325 Adler, Alan. "Pilot and Volvo Group add to public electric charging projects". FreightWaves. November 16,
2022. Available online: https://www.freightwaves.com/news/pilot-and-volvo-group-add-to-public-electric-charging-
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326 Ramey, Jay. "Three Truck Makers Will Build EV Charging Network". July 11, 2022. Autoweek. Available
online: https://www.autoweek.com/news/green-cars/a40574634/volvo-daimler-traton-ev-truck-charging-network/.

327 Tesla. Semi: The Future of Trucking. Available online: https://www.tesla.com/semi.

328 Joint Office of Energy and Transportation. "Private Sector Continues to Play Key Part in Accelerating Buildout
of EV Charging Networks." February 15, 2023. https://driveelectric.gOv/news/#private-investment.

329 Borras, Jo. "Volvo Trucks Building an Electric Semi Charging Corridor". CleanTechnica. July 16, 2022.
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330 WattEV. "WattEV Orders 50 Volvo VNR Electric Trucks". May 23, 2022. Available online:
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331 WattEV. "WattEV Breaks Ground on 21st Century Truck Stop". December 16, 2021. Available online:
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332 Zeem. "Zeem Solutions Launches First Electric Vehicle Transportation-As-A-Service Depot". March 30, 2022.
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service-depot/

333 Hampel, Carrie. "Heliox to be global charging partner for Paccar". Electrive.com. September 24, 2022. Available
online: https://www.electrive.com/2022/09/24/heliox-to-be-global-charging-partner-for-paccar/.

334 Morgan, Jason. "How Sysco Corp. plans to deploy 800 battery electric Class 8 trucks (and that's just the
beginning)". Fleet Equipment. November 14, 2022. Available online: https://www.fleetequipmentmag.com/sysco-
battery-electric-trucks/.

335 Nikola. "Nikola and ChargePoint Partner to Accelerate Charging Infrastructure Solutions". November 8, 2022.
Available online: https://nikolamotor.com/press_releases/nikola-and-chargepoint-partner-to-accelerate-charging-
infrastructure-solutions-2121.

336 BP. Press Release: "bp takes first major step into electrification in the US by acquiring EV fleet charging
provider AMPLY Power". December 7, 2021. Available online: https://www.bp.com/en/global/corporate/news-and-
insights/press-releases/bp-takes-first-maior-step-into-electrification-in-us-bv-acquiring-ev-fleet-charging-provider-
amplv-power.html.

337 BloombergNEF. "Next $100 Billion EV-Charger Spend to Be Super Fast." January 20, 2023. Accessed March
15, 2023. https://about.bnef.com/blog/next-100-billion-ev-charger-spend-to-be-super-fast/.

338 Hampleton. "Autotech & Mobility M&A market report 1H2023." 2023. Accessed March 5, 2023.
https://www.hampletonpartners.com/fileadmin/user_upload/Report_PDFs/Hampleton-Partners-Autotech-Mobility-
Report-lH2023-FINAL.pdf.

339 St. John, Alexa, and Nora Naughton. "Automakers need way more plug-in stations to make their EV plans work.
That has sparked a buyer frenzy as big charging players gobble up smaller ones." Insider, November 24, 2022.
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vehicle-demand-2022-11.

340 Joint Office of Energy and Transportation. "Private Sector Continues to Play Key Part in Accelerating Buildout
of EV Charging Networks." February 15, 2023. https://driveelectric.gOv/news/#private-investment.

341 North Carolina Office of the Governor. "Manufacturer of Electric Vehicle Charging Stations Selects Durham
County for New Production Facility". February 7, 2023. Available online: https://governor.nc.gov/news/press-
releases/2023/02/07/manufacturer-electric-vehicle-charging-stations-selects-durham-county -new-production-
facility.

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342 ZEV Task Force. "Multi-State Medium- and Heavy-Duty Zero-Emission Vehicle Action Plan: A Policy
Framework to Eliminate Harmful Truck and Bus Emissions". July 2022. Available online:
https://www.nescaum.org/documents/multi-state-medium-and-heaw-dutv-zev-action-plan-dual-page.pdf.

343 California Energy Commission. "CEC Approves $2.9 Billion Investment for Zero-Emission Transportation
Infrastructure". December 14, 2022. Available online: https://www.energy.ca.gov/news/2022-12/cec-approves-29-
billion-investment-zero-emission-transportation-infrastructure.

344 Joint Office of Energy and Transportation. "Private Sector Continues to Play Key Part in Accelerating Buildout
of EV Charging Networks." February 15, 2023. https://driveelectric.gOv/news/#private-investment.

345 Edison Electric Institute. Issues & Policy: National Electric Highway Coalition. Available online:
https://www.eei.org/en/issues-and-policv/national-electric-highwav-coalition.

346 U.S. Department of Energy. Florida Laws and Incentives - Utility/Private Incentives. Alternative Fuels Data
Center. Available online: https://afdc.energy.gov/laws/all?state=FL

347 U.S. Department of Energy. Commercial Electric Vehicle Charging Station Rebates—Nevada Energy.

Alternative Fuels Data Center. Available online: https://afdc.energy.gov/laws/12118.

348 Minjares, Ray, Felipe Rodriguez, Arijit Sen, and Caleb Braun. "Infrastructure to support a 100% zero-emission
tractor-trailer fleet in the United States by 2040". The International Council on Clean Transportation. September
2021. Available online: https://theicct.org/sites/default/files/publications/ze-tractor-trailer-fleet-us-hdvs-sept21.pdf.

349 Ibid.

350 McKenzie, Lucy, James Di Filippo, Josh Rosenberg, and Nick Nigro. "U.S. Vehicle Electrification Infrastructure
Assessment: Medium- and Heavy-Duty Truck Charging". Atlas Public Policy. November 12, 2021. Available
online: https://atlaspolicv.eom/wp-content/uploads/2021/l 1/2021-11-

12 Atlas US Electrification Infrastructure Assessment MD-HD-trucks.pdf.

351 Goldman School of Public Policy, University of California Berkeley. "2035, The Report—Transportation:
Plummeting Costs and Dramatic Improvements in Batteries Can Accelerate Our Clean Transportation Future". April
2021. Available online: http://www.2035report.eom/transportation/wp-content/uploads/2020/05/2035Report2.0-
Lpdf?hsCtaTrackmg=544e8e73-752a-40ee-b3a5-90e28d5f2el8%7C81c0077a-d01d-45b9-a338-fcaef78a20e7

352 NARUC. "Electric Vehicles: Key Trends, Issues, and Considerations for State Regulators". October 2019.
Available online: https://pubs.naruc.org/pub/32857459-0005-B8C5-95C6-1920829CABFE.

353 Ibid.

354 ZEV Task Force. "Multi-State Medium- and Heavy-Duty Zero-Emission Vehicle Action Plan: A Policy
Framework to Eliminate Harmful Truck and Bus Emissions". July 2022. Available online:
https://www.nescaum.org/documents/multi-state-medium-and-heaw-dutv-zev-action-plan-dual-page.pdf

355 McLaren, Joyce, Nicholas Laws, and Kate Anderson. "Identifying Potential Markets for Behind-the-Meter
Battery Energy Storage: A Survey of U.S. Demand Charges". National Renewable Energy Lab. August 2017.
Available online: https://www.nrel.gov/docs/fvl7osti/68963.pdf.

356 Satterfield, Chris and Nick Nigro. "Assessing Financial Barriers to Adoption of Electric Trucks: A Total Cost of
Ownership Analysis". Atlas Public Policy. February 2020. Available online: https://atlaspolicv.com/wp-
content/uploads/2020/02/Assessing-Financial-Barriers-to-Adoption-of-Electric-Trucks.pdf.

357 U.S. DOE Alternative Fuels Data Center. "Charging Infrastructure Operation and Maintenance." Available
online: https://afdc.energy. gov/fuels/electricity_infrastructure_maintenance_and_operation.html.

358 California Energy Commission. Electric Vehicle Charging Infrastructure Assessment—AB 2127. Available
online: https://www.energv.ca.gov/programs-and-topics/programs/electric-vehicle-charging-infrastructure-
assessment-ab-2127.

359 Halvorson, Bengt. "$250 CCS adapter lets Tesla EVs roam other charging networks". Green Car Reports.
September 25, 2022. Available online: https://www.greencarreports.com/news/1137268 tesla-ccs-adapter-north-
america-up-to-250-kw.

360 88 FR 12724. February 28, 2023. Available online: https://www.federalregister.gov/documents/2023/02/28/2023-
03500/national-electric-vehicle-infrastructure-standards-and-requirements.

361 SAE International. "Megawatt Charging System for Electric Vehicles J3271". Available online:
https://www.sae.org/standards/content/i3271/

362 California Energy Commission. Electric Vehicle Charging Infrastructure Assessment—AB 2127. Available
online: https://www.energv.ca.gov/programs-and-topics/programs/electric-vehicle-charging-infrastructure-
assessment-ab-2127.

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363 88 FR 12724. February 28, 2023. Available online: https://www.federalregister.gov/documents/2023/02/28/2023-
03500/national-electric-vehicle-infrastructure-standards-and-requirements.

364 Kane, Mark. "CharIN Officially Launches The Megawatt Charging System (MCS)". Inside EVs. June 15, 2022.
Available online: https://insideevs.com/news/592360/megawatt-charging-svstem-mcs-launch/.

365 National Renewable Energy Laboratory (NREL). "Medium- and Heavy-Duty Electric Vehicle Charging".
Available online: https://www.nrel.gov/transportation/medium-heaw-dutv-vehicle-charging.html.

366 Alexander, Matt et al. California Energy Commission. "Assembly Bill 2127 Electric Vehicle Charging
Infrastructure Assessment Analyzing Charging Needs to Support Zero-Emission Vehicles in 2030". July 2021.
Available online: https://www.energy.ca.gov/programs-and-topics/programs/electric-vehicle-charging-
infrastructure - assessment-ab-2127.

367 Alexander, Matt et al. California Energy Commission. "Assembly Bill 2127 Electric Vehicle Charging
Infrastructure Assessment Analyzing Charging Needs to Support Zero-Emission Vehicles in 2030". July 2021.
Available online: https://www.energy.ca.gov/programs-and-topics/programs/electric-vehicle-charging-
infrastructure - assessment-ab-2127.

368 Electrify America. "2021 National Annual Report to U.S. EPA". April 30, 2022. Available online:
https://media.electrifvamerica.com/assets/documents/original/872-2021AnnualReportNationalPublicFINAL.pdf.

369 Hickerson, Heather and Hannah Goldsmith. CALIFORNIA GOVERNOR'S OFFICE OF BUSINESS AND
ECONOMIC DEVELOPMENT. "Electric Vehicle Charging Station Permitting Guidebook". January, 2023.
Available online: https://static.business.ca.gov/wp-content/uploads/2019/12/GoBIZ-EVCharging-Guidebook.pdf

370 Alexander, Matt et al. California Energy Commission. "Assembly Bill 2127 Electric Vehicle Charging
Infrastructure Assessment Analyzing Charging Needs to Support Zero-Emission Vehicles in 2030". July 2021.
Available online: https://www.energy.ca.gov/programs-and-topics/programs/electric-vehicle-charging-
infrastructure - assessment-ab-2127.

371 Alexander, Matt et al. California Energy Commission. "Assembly Bill 2127 Electric Vehicle Charging
Infrastructure Assessment Analyzing Charging Needs to Support Zero-Emission Vehicles in 2030". July 2021.
Available online: https://www.energy.ca.gov/programs-and-topics/programs/electric-vehicle-charging-
infrastructure - assessment-ab-2127.

372 Borlaug, B., Muratori, M., Gilleran, M. et al. "Heavy-duty truck electrification and the impacts of depot charging
on electricity distribution systems". Nat Energy 6, 673-682 (2021). Available online:

https ://www. nature. com/articles/s41560-021-00855-0.

373 Ibid.

374 Alexander, Matt et al. California Energy Commission. "Assembly Bill 2127 Electric Vehicle Charging
Infrastructure Assessment Analyzing Charging Needs to Support Zero-Emission Vehicles in 2030". July 2021.
Available online: https://www.energy.ca.gov/programs-and-topics/programs/electric-vehicle-charging-
infrastructure - assessment-ab-2127.

375 Pournazeri, Sam. "Criteria to consider when siting EV charging infrastructure for medium- and heavy-duty
vehicles". ICF. April 28, 2022. Available online: https://www.icf.com/insights/transportation/medium-heavy-duty-
ev-charging.

376 Hernandez, Mari. IREC "Paving the Way Emerging Best Practices for Electric Vehicle Charger Interconnection".
June 2022. Available online: https://irecusa.org/wp-content/uploads/2022/06/EV-Paper-3-Charger-
Interconnection_compressed.pdf.

377 Hernandez, Mari. IREC "Paving the Way Emerging Best Practices for Electric Vehicle Charger Interconnection".
June 2022. Available online: https://irecusa.org/wp-content/uploads/2022/06/EV-Paper-3-Charger-
Interconnection_compressed.pdf.

378 Schwartz, Lisa. "State Regulatory Approaches for Distribution Planning". National Association of State Utility
Consumer Advocates 2022 Mid-Year Meeting. June 14, 2022. Available online: https://www.nasuca.org/wp-
content/uploads/2021/10/NASUCA-Schwartz-distribution-planning-20220610.pdf.

379 Schwartz, Lisa. "State Regulatory Approaches for Distribution Planning". National Association of State Utility
Consumer Advocates 2022 Mid-Year Meeting. June 14, 2022. Available online: https://www.nasuca.org/wp-
content/uploads/2021/10/NASUCA-Schwartz-distribution-planning-20220610.pdf.

380 Nuvve and Enel X. "BRIEF - Automated Load Management for EVSE Interconnection". July 14, 2020.
Available online: https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M354/K191/354191323.PDF.

381 Alexander, Matt et al. California Energy Commission. "Assembly Bill 2127 Electric Vehicle Charging
Infrastructure Assessment Analyzing Charging Needs to Support Zero-Emission Vehicles in 2030". July 2021.

100

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Available online: https://www.energy.ca.gov/programs-and-topics/programs/electric-vehicle-charging-
infrastructure-assessment-ab-2127.

382 FreeWire Technologies. "Mobi EV Charger Data Sheet". 2023 Available online:
https://freewiretech.com/products/mobi-ev/.

383 Lightning eMotors. "Lightning energy Lightning Mobile Go anywhere power for a go anywhere world." January
2023. Available online: https://lightningemotors.com/wp-
content/uploads/2023/01/LE_Lightning_M obile_sheet_Jan2023_vl_online.pdf.

384 Alexander, Matt et al. California Energy Commission. "Assembly Bill 2127 Electric Vehicle Charging
Infrastructure Assessment Analyzing Charging Needs to Support Zero-Emission Vehicles in 2030". July 2021.
Available online: https://www.energy.ca.gov/programs-and-topics/programs/electric-vehicle-charging-
infrastructure - assessment-ab-2127.

385 Morris, Charles. "Solar-powered off-grid EV charging stations offer surprisingly attractive cost advantages".
Charged EV Fleet & Infrastructure News. December 13, 2022. Available online:

https://chargedevs.com/features/solar-powered-off-grid-ev-charging-stations-offer-surprisingly-attractive-cost-
advantages/.

386 U.S. Department of Energy, Vehicle Technologies Office. "Hydrogen Basics". Alternative Fuels Data Center.
Available online: https://afdc.energv.gov/fuels/hvdrogen basics.html.

387 U.S. Department of Energy, Fuel Cell Technologies Office. "Fuel Cells". November 2015. Available online:
https://www.energv.gov/sites/prod/files/2015/ll/f27/fcto fuel cells fact sheet.pdf.

388 U.S. Department of Energy, Hydrogen and Fuel Cell Technologies Office. "Fuel Cell Systems". Available
online: https://www.energy.gov/eere/fuelcells/fuel-cell-

svstems#:~:text=The%20fuel%20cell%20stack%20isis%20insufficient%20for%20most%20applications.

389 U.S. Department of Energy, Hydrogen and Fuel Cell Technologies Office. "Types of Fuel Cells". Available
online: https://www.energy.gov/eere/fuelcells/types-fuel-

cells#:~:text=PEM%20fuel%20cells%20operate%20atcomponents%2C%20resulting%20in%20better%20durabilitv

390 U.S. Department of Energy, Hydrogen and Fuel Cell Technologies Office. "Parts of a Fuel Cell". Available
online: https://www.energv.gov/eere/fuelcells/parts-fuel-cell.

391 Hoeflinger, Johannes and Peter Hofmann. "Air mass flow and pressure optimization of a PEM fuel cell range
extender system". International Journal of Hydrogen Energy. Volume 45:53. October 02020. Available online:
https://www.sciencedirect.com/science/article/pii/S0360319920327841.

392 Pardhi, Shantanu, et. al. "A Review of Fuel Cell Powertrains for Long-Haul Heavy-Duty Vehicles: Technology,
Hydrogen, Energy and Thermal Management Systems". Energies. December 2022. Available online:
https://www.mdpi.com/1996-1073/15/24/9557.

393 Hyfindr. "Fuel Cell Stack". Available online: https://hyfindr.com/fuel-cell-stack/.

394 U.S .Environmental Protection Agency. "Assessment of Fuel Cell Technologies at Ports". Prepared for EPA by
Eastern Research Group, Inc. July 2022. Available online:

https://nepis.epa.gov/Exe/Zy PDF.cgi?Dockey=P1015AQX.pdf.

395 Ibid.

396 US Drive. "Hydrogen Production Tech Team Roadmap". November 2017. Available online:
https://www.energy.gov/eere/vehicles/articles/us-drive-hydrogen-production-technical-team-roadmap.

397 Nguyen, Huu Linh, et. al. "Review of the Durability of Polymer Electrolyte Membrane Fuel Cell in Long-Term
Operation: Main Influencing Parameters and Testing Protocols". Energies. July 2021. Available online:
https://www.mdpi.com/1996-1073/14/13/4048.

398 International Organization for Standardization. "ISO 14687: 2019, Hydrogen fuel quality—Product
specification". November 2019. Available online: https://www.iso.org/standard/69539.html.

399 Hyfindr. "Fuel Cell Stack". Available online: https://hyfindr.com/fuel-cell-stack/.

400 Pardhi, Shantanu, et. al. "A Review of Fuel Cell Powertrains for Long-Haul Heavy-Duty Vehicles: Technology,
Hydrogen, Energy and Thermal Management Systems". Energies. December 2022. Available online:
https://www.mdpi.com/1996-1073/15/24/9557.

401 Baroutaji, Ahmad, et. al. "Advancements and prospects of thermal management and waste heat recovery of
PEMFC". Interational Journal ofThermofluids: 9. February 2021. Available online:
https://www.sciencedirect.com/science/article/pii/S2666202721000021.

101

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402 Nguyen, Huu Linh, et. al. "Review of the Durability of Polymer Electrolyte Membrane Fuel Cell in Long-Term
Operation: Main Influencing Parameters and Testing Protocols". Energies. July 2021. Available online:
https://www.mdpi.com/1996-1073/14/13/4048.

403 Marcinkoski, Jason et. al. "DOE Advanced Truck Technologies: Subsection of the Electrified Powertrain
Roadmap—Technical Targets for Hydrogen-Fueled Long-Haul Tractor-Trailer Trucks. October 31, 2019. Available
online: https://www.hydrogen.energy.gov/pdfi/19006_hydrogen_class8_long_haul_truck_targets.pdf.

404 Deloitte China. "Fueling the Future of Mobility: Hydrogen and fuel cell solutions for transportation, Volume 1".
2020. Available online: https://www2.deloitte.com/content/dam/Deloitte/cn/Documents/finance/deloitte-cn-fueling-
the-future-of-mobilitv-en-200101 .pdf.

405 Ibid.

406 James, Brian D., et. al. "Fuel Cell Truck System Cost Analysis". Strategic Analysis Inc. July 2018. Available
online: https://www.energv.gov/sites/prod/files/2018/08/f54/fcto-truck-workshop-2018-10-iames.pdf.

407 U.S. Department of Energy, Advanced Manufacturing & Industrial Decarbonization Office. "Critical Minerals &
Materials". Available online: https://www.energy. gov/eere/amo/critical-minerals-materials.

408 Berkeley Lab. "Strategies for Reducing Platinum Waste in Fuel Cells. November 2021. Available online:
https://als.lbl.gov/strategies-for-reducing-platinum-waste-in-fuel-cells/.

409 Islam, Ehsan Sabri, Ram Vijayagopal, Aymeric Rousseau. "A Comprehensive Simulation Study to Evaluate
Future Vehicle Energy and Cost Reduction Potential". Report to the U.S. Department of Energy, Contract
ANL/ESD-22/6. October 2022. Available online: https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-
benefits/.

410 U.S. Department of Energy, Alternative Fuels Data Center. "How Do Fuel Cell Electric Vehicles Work Using
Hydrogen?" Available online: https://afdc.energy.gov/vehicles/how-do-fuel-cell-electric-cars-work.

411 Sharpe, Ben and Hussein Basma. "A Meta-Study of Purchase Costs for Zero-Emission Trucks". The International
Council on Clean Transportation. February 2022. Available online: https://theicct.org/publication/purchase-cost-ze-
trucks-feb22/.

412 Langmi, Henrietta et. al. "Hydrogen storage". Electrochemical Power Sources: Fundamentals, Systems, and
Applications. 2022. Portion available online: https://www.sciencedirect.com/topics/engineering/compressed-
hydrogen-

storage#:~:text=There%20are%20four%20standard%20types,cylinders%20with%20nonload%20bearing%20nonme
tallic.

413 U.S. Department of Energy, Fuel Cell Technologies Office. "Hydrogen Storage". March 2017. Available online:
https://www.energy.gov/sites/prod/files/2017/03/f34/fcto-h2-storage-fact-sheet.pdf.

414 Houchins, Cassidy and Brian D. James. "2019 DOE Hydrogen and Fuel Cell Program Review: Hydrogen Storage
Cost Analysis". Strategic Analysis. May 2019. Available online:
https://www.hvdrogen.energv.gov/pdfs/reviewl9/stl00 iames 2019 o.pdf.

415 Basma, Hussein and Felipe Rodriquez. "Fuel cell electric tractor-trailers: Technology overview and fuel
economy". Working Paper 2022-23. The International Council on Clean Transportation. July 2022. Available
online: https://theicct.org/wp-content/uploads/2022/07/fuel-cell-tractor-trailer-tech-fuel-jul22.pdf.

416 NextEnergy. "Hydrogen Heavy Duty Vehicle Industry Group". Available online:
https://nextenergv.org/hvdrogen-heaw-dutv-vehicle-industrv-group/.

417 Marcinkoski, Jason et. al. "DOE Advanced Truck Technologies: Subsection of the Electrified Powertrain
Roadmap—Technical Targets for Hydrogen-Fueled Long-Haul Tractor-Trailer Trucks. October 31, 2019. Available
online: https://www.hydrogen.energy.gov/pdfs/19006_hydrogen_class8_long_haul_truck_targets.pdf.

418 Martineau, Rebecca. "Fast Flow Future for Heavy-Duty Hydrogen Trucks: Expanded Capabilities at NREL
Demonstration High-Flow-Rate Hydrogen Fueling for Heavy-Duty Applications". National Renewable Energy Lab.
June 2022. Available online: https://www.nrel.gov/news/program/2022/fast-flow-future-heavv-duty-hvdrogen-
trucks.html.

419 Kast, James et. al. "Designing hydrogen fuel cell electric trucks in a diverse medium and heavy duty market".
Research in Transportation Economics: Volume 70. October 2018. Available online:
https://www.sciencedirect.com/science/article/pii/S0739885916301639.

420 Basma, Hussein and Felipe Rodriquez. "Fuel cell electric tractor-trailers: Technology overview and fuel
economy". Working Paper 2022-23. The International Council on Clean Transportation. July 2022. Available
online: https://theicct.org/wp-content/uploads/2022/07/fuel-cell-tractor-trailer-tech-fuel-iul22.pdf.

102

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421 Basma, Hussein and Felipe Rodriquez. "Fuel cell electric tractor-trailers: Technology overview and fuel
economy". Working Paper 2022-23. The International Council on Clean Transportation. July 2022. Available
online: https://theicct.org/wp-content/uploads/2022/07/fuel-cell-tractor-trailer-tech-fuel-iul22.pdf.

422 Ibid.

423 Daimler Truck. "Development milestone: Daimler Truck tests fuel-cell truck with liquid hydrogen". June 2022.
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428 Baird, Austin R. et. al. "Federal Oversight of Hydrogen Systems". Sandia National Laboratories. March 2021.
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456 U.S. Department of Energy, Hydrogen and Fuel Cell Technologies Office. "Hydrogen Production". Available
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457 Chukwudi Tashie-Lewis, Bernard and Somtochukwu Godfrey Nnabuife. "Hydrogen Production, Distribution,
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462 U.S. Department of Energy, Hydrogen and Fuel Cell Technologies Office. "Hydrogen Production: Natural Gas
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464 U.S. Department of Energy, Hydrogen and Fuel Cell Technologies Office. "Hydrogen Production: Biomass
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470 U.S. Department of Energy. "Bulk Storage of Gaseous Hydrogen: 2022 Workshop Summary Report". February
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474 U.S. Department of Energy, Hydrogen and Fuel Cell Technologies Office. "DOE National Clean Hydrogen
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hvdrogen-strategv-roadmap.pdf.

475 U.S. Department of Energy, Office of Clean Energy Demonstrations. "OCED Funding Opportunity
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477 U.S. Department of Energy, Office of Clean Energy Demonstrations. "OCED Funding Opportunity
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Available online: https://oced-exchange.energv.gOv/Default.aspx#FoaId4dbbd966-7524-4830-b883-450933661811.

478 U.S. Department of Energy. "Pathways to Commercial Liftoff: Clean Hydrogen". March 2023. Available online:
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479 See "H2_consumption_NREL.pdf" contained in the docket for this rule and last accessed on January 25, 2023.

480 U.S. Department of Energy, Hydrogen and Fuel Cell Technologies Office. "Hydrogen Delivery". Available
online: https://www.energy.gov/eere/fuelcells/hydrogen-delivery.

481 U.S. Department of Energy, Hydrogen and Fuel Cell Technologies Office. "Hydrogen Pipelines". Available
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pipelines#:~:text=Approximatelv%201%2C600%20miles%20of%20hvdrogen,as%20the%20Gulf%20Coast%20regi
on.

482 Ogden, Joan et. al. "Natural gas as a bridge to hydrogen transportation fuel: Insights from the literature". Energy
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483 U.S. Department of Energy, Hydrogen and Fuel Cell Technologies Office. "Hydrogen Tube Trailers". Available
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484 U.S. Department of Energy. "Pathways to Commercial Liftoff: Clean Hydrogen". March 2023. Available online:
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485 Mulder, Brandon. "Liquid hydrogen seen as 'holy grail' for hydrogen uptake in the mobility sector: Linde COO".
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486 U.S. Department of Energy, Hydrogen and Fuel Cell Technologies Office. "Liquid Hydrogen Delivery".
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487 Jimmy Li, Xianming et. al. "Paths to low-cost hydrogen energy at a scale for transportation applications in the
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488 U.S. Department of Energy, Hydrogen and Fuel Cell Technologies Office. "Hydrogen Delivery". Available
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489 Quimby, Tom. "Producing hydrogen on-site 'gives flexibility now'". CCJ. July 27, 2022. Available online:
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490 U.S. Department of Energy, Alternative Fuels Data Center. "Hydrogen Fueling Stations". Available online:
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491 U.S. Department of Energy. "Pathways to Commercial Liftoff: Clean Hydrogen". March 2023. Available online:
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492 U.S. Department of Energy. "U.S. DOE Hydrogen and Fuel Cell Activities". November 7, 2022. Available
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493 U.S. Department of Energy, Alternative Fuels Data Center. "Hydrogen Fueling Station Locations". Available
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494 U.S. Department of Transportation, Federal Highway Administration. "Alternative Fuel Corridors: Hydrogen".
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Round+1.2.3.4.5+and+6')#.

495 U.S. Department of Transportation, Federal Highway Administration. "Alternative Fuel Corridors: Frequently
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https://www.fhwa.dot.gov/environment/alternative_fuel_corridors/resources/faq/.

496 Minjares, Ray et. al. "Infrastructure to support a 100% zero-emission tractor-trailer fleet in the United States by
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497 West Coast Collaborative. "Alternative Fuels: West Coast Collaborative Alternative Fuel Infrastructure Corridor
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498 Mikulin, John (EPA Region 9). "Medium and Heavy-Duty Alternative Fuel Infrastructure Planning in the
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499 IPCC. (2021). Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the Sixth
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5°° Derwen^ r ^ et ai (2006). Global environmental impacts of the hydrogen economy. International Journal of
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501 Forster, Piers, et al. (2018). Changes in Atmospheric Constituents and in Radiative Forcing. IPCC. p. 106.
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502 Ocko, Ilissa B. and Steven P. Hamburg, Environmental Defense Fund. "Climate consequences of hydrogen
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503 Hydrogen Council and McKinsey & Company. "Hydrogen Insights 2022: An updated perspective on hydrogen
market development and actions required to unlock hydrogen at scale". September 2022. Available online:
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504 Arrigoni, A. and Bravo Diaz, L., Hydrogen emissions from a hydrogen economy and their potential global
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505 Fan, Zhiyuan, et. al. "Hydrogen Leakage: A Potential Risk for the Hydrogen Economy". Columbia SIPA, Center
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506 Koch blank, Thomas, et. al. "Hydrogen Reality Check #1: Hydrogen is Not a Significant Warming Risk". Rocky
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507 Frazer-Nash Consultancy. "Fugitive Hydrogen Emissions in a Future Hydrogen Economy". March 2022.
Available online:

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1067137/fugitive-
hydrogen-emissions-future-hydrogen-economy.pdf.

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Chapter 2 Technology Assessment

2.1 Introduction

This chapter describes the operational characteristics and costs that we used to estimate
heavy-duty ZEV technology feasibility and adoption rates that form the technology package that
supports the calculated proposed standards for MYs 2027 through 2032. These costs are typically
direct manufacturing costs (DMC), but also retail price equivalents (RPE), which include DMC
and indirect costs, in some cases as appropriate. Additional discussion of DMC, indirect costs,
and RPE can be found in Chapter 3.2 of the DRIA. To conduct the analysis, a flexible
spreadsheet-based framework was developed in-house called the Heavy-Duty Technology
Resource Use Case Scenario (HD TRUCS) tool.1

While we acknowledge and are aware of other tools and models that perform related functions
and have gathered important insights from them,11'111'1'2!® TRUCS defines EPA's understanding
of heavy-duty vehicle performance, based on data and resources available to EPA at the time of
the analysis.

Many technologies and powertrains have been demonstrated and are considered technically
feasible for HD vehicles. Thus, a diverse range of technologies may be used to comply with the
proposed standards to reduce GHG emissions including ICE, hybrid, and plug-in hybrid
powertrains, hydrogen ICEs, BEVs, and FCEVs. The HD TRUCS analysis focuses on ZEV
technologies due their development since Phase 2 and the anticipated future improvements and
increase in use in the heavy-duty sector, as discussed in Chapter 1.1V

HD TRUCS evaluates the design features needed to meet the energy and power demands of
various HD vehicle types when using ZEV technologies. To build technology packages using
HD TRUCS, we created 101 representative vehicles in HD TRUCS that cover the full range of
weight classes within the scope of the proposed standards (i.e., Class 2b through 8 vocational
vehicles and tractors). The representative vehicles cover many aspects of work performed by the
industry. This work was translated into total energy and power demands per vehicle type based
on everyday use of HD vehicles, ranging from moving goods and people to mixing cement. We
then identified the technical properties required for a BEV or FCEV to meet the operational
needs of a comparable ICE HD vehicle/

I See Memorandum to docket EPA-HQ-OAR-2022-0985. "Heavy-Duty Technology Resource Use Case Scenario
Tool (HD TRUCS)". March 2023.

II For example, as cited in the endnotes: ACT Research's report mentions a proprietary Total Cost of Ownership
model; Ledna et. al uses the National Renewable Energy Laboratory's Transportation Energy & Mobility Pathway
Options Model (TEMPO) model; and California Air Resources Board's report refers to an assessment matrix
developed by the Truck and Engine Manufacturers Association (EMA). Chapter 2.1.2 also discusses our use of
Argonne National Laboratory's BEnefit ANalysis (BEAN) and Autonomie models.

III Mitchell, George. Memorandum to docket EPA-HQ-OAR-2022-0985. " ACT Research Co. LLC. "Charging
Forward" 2020-2040 BEV & FCEV Forecast & Analysis, updated December 2021.

lv BEVs and FCEVs may be well-suited to many heavy-duty applications because these technologies have high low-
end torque, which may provide benefits for heavy vehicles at low speeds.

v Heavy-duty vehicles are typically powered by a diesel-fueled compression-ignition (CI) engine, though the heavy-
duty market includes vehicles powered by gasoline-fueled spark-ignition (SI) engines and alternative -fueled ICEs.

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Since batteries can add weight and volume to a vehicle,3 we evaluated battery mass and
physical volume required to package a battery pack. If the performance needs of a BEV resulted
in a battery that was too large or heavy, then we did not consider the BEV for that application in
our technology package because of the impact on payload and, thus, potential work
accomplished relative to a comparable ICE vehicle."

To evaluate costs, including costs of compliance for manufacturers as well as user costs
related to purchasing and operating ZEVs, we sized vehicle components that are unique to ZEVs
to meet the work demands of each representative vehicle. We applied cost estimates to each
vehicle component based on sizing to assess the difference in total powertrain costs between the
ICE and ZEV powertrains. We accounted for the IRA battery tax credit and vehicle purchase tax
credit. We also compared operating costs due to fuel and electricity consumption as well as
vehicle maintenance and repair, and we included the cost to procure and install depot charging
infrastructure for BEVs. For FCEVs, similar to ICE vehicles' infrastructure and fuel costs, we
assumed hydrogen infrastructure costs were embedded in the cost of hydrogen fuel.

We relied on research and findings discussed in Chapter 1 and throughout Chapter 2 to
conduct the HD TRUCS analysis. For MYs 2027 through 2029, we focused primarily on BEV
technology. Research suggests that BEV technologies can become cost-competitive for some
duty cycles of HD vehicles by the late 2020s.4'5'6 Given that there are more BEV models
available today compared to FCEV models (e.g., see Chapters 1.7.5 and 1.7.6), we inferred that
BEV adoption is likely to happen sooner than the adoption of FCEV technology.

Starting in MY 2030, we also considered FCEV technology for select applications. BEV
technology is more efficient than FCEV technology but may not be suitable for all applications.
FCEVs are more efficient than diesel vehicles and can have shorter refueling times than
batteries/11 so we considered FCEVs in the technology packages for applications that travel
longer distances and/or carry heavier loads. This included coach buses, heavy-haul tractors,
sleeper cab tractors, and day cab tractors.

Though fuel cell technology is still emerging in HD vehicle applications, based on our review
of the literature , we believe that FCEVs are a viable ZEV technology for heavy-duty

We selected diesel-powered ICE vehicles as the baseline vehicle for the assessment in HD TRUCS in our analysis
because a diesel-fueled CI engine is broadly available for all of the 101 vehicle types and are more efficient than SI
engines.

V1 This does not necessarily mean that a BEV with a large battery weight and volume would not be technically
feasible for a given HD vehicle use, but rather this is an acknowledgement that we considered impacts of increased
battery size on feasibility considerations like payload capacity as well as cost and payback within the selection of
HD vehicle technologies for the technology packages.

vn Cunanan, Carlo et. al. "A Review of Heavy-Duty Vehicle Powertrain Technologies: Diesel Engine Vehicles,
Battery Electric Vehicles, and Hydrogen Fuel Cell Electric Vehicles". Clean Technol. Available online:
https://www.mdpi.eom/2571-8797/3/2/28.

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transportationV111'1X'X and will be available in the 2030 timeframe (see DRIA Chapter 1.7.5).X1'7'8'9
Inclusion of FCEVs in the technology packages starting in MY 2030 takes into consideration
additional lead time to allow manufacturers to design, develop, and manufacture HD FCEV
models. Fuel cell technology in other sectors has been in existence for decades10 and has been
demonstrated to be technically feasible in heavy-duty transportation.11 Interim research and
development (R&D) technical targets and projects (see DRIA Chapter 1.7.7) are in place to
facilitate necessary improvements in the performance, durability, and costs of hydrogen-fueled
long-haul HD tractors in 2030.12 With substantial federal investment in low-GHG hydrogen
production (see DRIA Chapter 1.3.2), we anticipate that the price of hydrogen fuel will drop
enough by 2030 to make HD FCEVs cost-competitive with comparable ICE vehicles for some
duty cycles. Hydrogen infrastructure is expected to need the additional time prior to MY 2030 to
further develop, as discussed in greater detail in DRIA Chapter 1.8, but we expect the refueling
needs can be met by MY 2030.13 We also recognize the impact regulations can have on
technology and refueling infrastructure development and deployment.

After considering operational characteristics and costs in 2021 dollars, we determined the
payback period, which is the number of years it would take to offset any incremental cost
increase of a ZEV over a comparable ICE vehicle. Lastly, technology adoption rates for BEVs or
FCEVs were selected based on the payback period.

From a vehicle's emission standard compliance perspective, BEVs and FCEVs both emit
zero grams of CO2 per ton-mile at the tailpipe. Our HD TRUCS analysis in this chapter focuses
on these two technologies to demonstrate the appropriateness of the proposed HD vehicle GHG
emission standards, but there are other technologies as described in Chapter 1 that can reduce
CO2 emissions, including H2 fueled ICE vehicles that also emit 0 g CCh/ton-mile at the tailpipe.
Under the proposed rule, manufacturers may choose to produce the technologies that work best
for their business case and the operator's needs in meeting the proposed performance-based
standards.

The remainder of Chapter 2.1 provides an overview of the HD TRUCS tool structure.

Chapters 2.1 through 2.6 discuss tool inputs used to compare diesel and ZEV technologies.
Chapter 2.2 explains how we established benchmark performance requirements for each HD
TRUCS vehicle, independent of the powertrain. Chapter 2.3 describes diesel vehicle
components, upfront technology costs, diesel fuel consumption, and operational costs. Chapter
2.4 describes BEV components, how components were sized in HD TRUCS to meet the
performance requirements of heavy-duty vehicles, upfront technology costs, BEV energy
consumption, and operational costs. Chapter 2.5 describes FCEV components, how components
were sized in HD TRUCS to meet the performance requirements of heavy-duty vehicles, upfront

vm Mihelic, Rick et. al. "Making Sense of Heavy-Duty Hydrogen Fuel Cell Tractors". North American Council for
Freight Efficiency. December 16, 2020. Available online: https://nacfe.org/research/electric-trucks/making-sense-
of-heavy-duty-hydrogen-fuel-cell-tractors/.

K Cunanan, Carlo et. al. "A Review of Heavy-Duty Vehicle Powertrain Technologies: Diesel Engine Vehicles,
Battery Electric Vehicles, and Hydrogen Fuel Cell Electric Vehicles". Clean Technol. Available online:
https://www.mdpi.eom/2571-8797/3/2/28.

x Cullen et. al. "New roads and challenges for fuel cells in heavy-duty transportation". Nature Energy. March 25,
2021. Available online: https://www.nature.com/articles/s41560-021-00775-z.

X1 For example, California's Advanced Clean Fleets Regulation requires that 10% of sleeper cab tractors and
specialty vehicles must be zero-emission by 2030. We note that although our technology package considers FCEVs
for specific HD applications, a diverse range of technologies may be used to comply with the proposed standards.

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technology costs, FCEV energy consumption, and operational costs. Chapter 2.6 contains a
discussion of BEV charging and infrastructure. Chapter 2.7 summarizes the methodologies used
in HD TRUCS to assess energy consumption of heavy-duty vehicles and ZEVs and evaluate
technology feasibility, payback, and adoption rates in the timeframe of this rulemaking. Chapter
2.8 shows the results of the analysis. Chapter 2.9 summarizes the proposed standards based on a
technology package that includes the resulting adoption rates of ZEVs.

2.1.1 HD TRUCS Vehicle Types

HD TRUCS includes 101 heavy-duty vehicle types that are representative of the wide range
of duty cycles and use cases in the HD industry. These 101 categories encompass 22 different
vehicle applications, which are further disaggregated by weight class, duty cycle, and daily
vehicle miles traveled (VMT).

The initial list of HD TRUCS vehicles was based on work the Truck and Engine
Manufacturers Association (EMA) and California Air Resources Board (CARB) conducted for
CARB's Advanced Clean Trucks (ACT) Regulation.14 That assessment contained 87 "market
segments". We first consolidated the list, eliminated some of the more unique vehicles with
fewer than 100 sales in California (like mobile laboratories), and assigned operational
characteristics that correspond to the Urban, Multi-Purpose, and Regional duty cycles used in
EPA's Greenhouse Gas Emissions Model (GEM).X11'15 Secondly, we added additional vehicles to
reflect vehicle applications that were represented in EPA's 2019 Annual Production Volume
(PV) Reports into Engine and Vehicle Compliance Information Systems.16 Table 2-1 summarizes
the 101 unique vehicle types represented in HD TRUCS and how they are categorized, each with
a vehicle identifier (Vehicle ID)X111, HD TRUCS vehicle application, vehicle weight class,
MOVESxlv SourceTypelD and RegClassID, and GEM duty cycle category.

Table 2-1 HD TRUCS Vehicle Types

Vehicle ID

Vehicle Application

Weight
Class

MOVES
source
TypelD

MOVES
regClassID

GEM Duty Cycle5™'11

01V Amb C14-5 MP

Ambulance

4-5

LHD M

xn GEM is an EPA vehicle simulation tool used to certify HD vehicles. HD TRUCS uses the version GEM2, which
was developed for EPA's Phase 2 Greenhouse Gas rulemaking. A detailed description of GEM is beyond the scope
of this document but can be found in the Phase 2 RIA or in GEM documentation on EPA's website. For more
information about how GEM was used to simulate road load power requirements for various duty cycles over the
default road load profiles to estimate work performed by HD vehicles, please see Miller, Neil. Memorandum to
docket EPA-HQ-OAR-2022-0985. "Gem Inputs and Results". March 2023.

xm The last characters of some of the Vehicle IDs are inconsistent with the last characters of the some of the GEM
duty cycles; however, Vehicle ID is used only as a unique identifier and was not intended to specify the GEM duty
cycle. For example, for tractors, the last few characters at the end of the Vehicle ID are used to identify the
operational VMT range (short range are urban, medium range are multi-purpose, long haul are regional) to ensure
coverage of the HD industry. The GEM Duty Cycle column lists the correct GEM duty cycle for each vehicle.
Xlv MOVES is EPA's MOtor Vehicle Emissions Simulator, a state-of-the-art emission modeling system that
estimates emissions for mobile sources at the national, county, and project level for criteria air pollutants,
greenhouse gases, and air toxics.

xv Each tractor in HD TRUCS was assigned a GEM Duty Cycle for a Low Roof Tractor to match the axle energy
more closely from GEM to ZEV vehicles that are currently in production. We expect that the axle energy of future
model year vehicles in the time frame of this rule will be more efficient than current vehicles, but in the absence of

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Vehicle ID

Vehicle Application

Weight
Class

MOVES
source
TypelD

MOVES
regClassID

GEM Duty Cycle5™'11

02V Amb C12b-3 MP

Ambulance

2b-3

LHD M

03V Amb C14-5 U

Ambulance

4-5

LHD U

04V Amb C12b-3 U

Ambulance

2b-3

LHD U

05T Box C18 MP

Box Truck

HHD M

06T Box C18 R

Box Truck

HHD R

07T Box C16-7 MP

Box Truck

6-7

MHD M

08T Box C16-7 R

Box Truck

6-7

MHD R

09T Box C18 U

Box Truck

HHD U

10T Box C16-7 U

Box Truck

6-7

MHD U

1 IT Box C12b-3 U

Box Truck

2b-3

LHD U

12T Box C12b-3 R

Box Truck

2b-3

LHD R

13T Box C12b-3 MP

Box Truck

2b-3

LHD M

14T Box C14-5 U

Box Truck

4-5

LHD U

15T Box C14-5 R

Box Truck

4-5

LHD R

16T Box C14-5 MP

Box Truck

4-5

LHD M

17B Coach C18 R

Coach Bus

18B Coach C18 MP

Coach Bus

19C Mix C18 MP

Cement Mixer

Concrete Mixer

20T Dump C18 U

Dump Truck

HHD U

21T Dump C18 MP

Dump Truck

HHD M

22T Dump C16-7 MP

Dump Truck

6-7

MHD M

23T Dump C18 U

Dump Truck

HHD U

24T Dump C16-7 U

Dump Truck

6-7

MHD U

25T Fire C18 MP

Fire Truck

HHD M

26T Fire C18 U

Fire Truck

HHD U

27T Flat C16-7 MP

Flatbed/Stake Truck

6-7

MHD M

28T Flat C16-7 R

Flatbed/Stake Truck

6-7

MHD R

29T Flat C16-7 U

Flatbed/Stake Truck

6-7

MHD U

30Tractor DC C18 MP

Port Dray age Tractor

C8 DC LR

31 Tractor DC C16-7 MP

Port Dray age Tractor

6-7

C7 DC LR

32Tractor DC C18 U

Port Dray age Tractor

C8 DC LR

3 3 Tractor DC C16-7 U

Port Dray age Tractor

6-7

C7 DC LR

34T Ref C18 MP

Refuse

Refuse Truck

35T Ref C16-7 MP

Refuse

6-7

Refuse Truck

36T Ref C18 U

Refuse

Refuse Truck

37T Ref C16-7 U

Refuse

6-7

Refuse Truck

38RV C18 R

39RV C16-7 R

6-7

MHD R

40RV C14-5 R

4-5

LHD R

41RV C12b-3 R

2b-3

LHD R

42RV C18 MP

43RV C16-7 MP

6-7

MHD M

44RV C14-5 MP

4-5

LHD M

45RV C12b-3 MP

2b-3

LHD M

46B School C18 MP

School Bus

47B School C16-7 MP

School Bus

6-7

School Bus

48B School C14-5 MP

School Bus

4-5

LHD M

49B School C12b-3 MP

School Bus

2b-3

LHD M

available data, we have chosen to align our most efficient GEM simulation result of a Low Roof Tractor to each
tractor category as this result is the closest to electric HD vehicles currently in production.

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Vehicle ID

Vehicle Application

Weight
Class

MOVES
source
TypelD

MOVES
regClassID

GEM Duty Cycle5™'3

5OB School C18 U

School Bus

5 IB School C16-7 U

School Bus

6-7

School Bus

52B School C14-5 U

School Bus

4-5

LHD U

53B School C12b-3 U

School Bus

2b-3

LHD U

54B Shuttle C14-5 MP

Shuttle Bus

4-5

LHD M

55B Shuttle C12b-3 MP

Shuttle Bus

2b-3

LHD M

56B Shuttle C14-5 U

Shuttle Bus

4-5

LHD U

57B Shuttle C12b-3 U

Shuttle Bus

2b-3

LHD U

58B Shuttle C16-7 MP

Shuttle Bus

6-7

MHD M

59B Shuttle C16-7 U

Shuttle Bus

6-7

MHD U

60S Plow C16-7 MP

Snow Plow

6-7

MHD M

61S Plow C18 MP

Snow Plow

HHD M

62S Plow C16-7 U

Snow Plow

6-7

MHD U

63 S Plow C18 U

Snow Plow

HHD U

64V Step C16-7 MP

Step Van

6-7

MHD M

65V Step C14-5 MP

Step Van

4-5

LHD M

66V Step C12b-3 MP

Step Van

2b-3

LHD M

67V Step C16-7 U

Step Van

6-7

MHD U

68V Step C14-5 U

Step Van

4-5

LHD U

69V Step C12b-3 U

Step Van

2b-3

LHD U

70S Sweep C16-7 U

Street Sweeper

6-7

MHD U

71T Tanker C18 R

Tanker Truck

HHD R

72T Tanker C18 MP

Tanker Truck

HHD M

73T Tanker C18 U

Tanker Truck

HHD U

74T Tow C18 R

Tow Truck

HHD R

75T Tow C16-7 R

Tow Truck

6-7

MHD R

76T Tow C18 U

Tow Truck

HHD U

77T Tow C16-7 U

Tow Truck

6-7

MHD U

78Tractor SC C18 MP

Sleeper Cab Tractor

C8 SC LR

79Tractor SC C18 R

Sleeper Cab Tractor

C8 SC LR

80Tractor DC C18 HH

Day Cab Tractor

C8 HH

81 Tractor DC C17 R

Day Cab Tractor

C7 DC LR

82Tractor DC C18 R

Day Cab Tractor

C8 DC LR

83 Tractor DC C17 U

Day Cab Tractor

C7 DC LR

84Tractor DC C18 U

Day Cab Tractor

C8 DC LR

85B Transit C18 MP

Transit Bus

86B Transit C16-7 MP

Transit Bus

6-7

Transit Bus

87B Transit C18 U

Transit Bus

88B Transit C16-7 U

Transit Bus

6-7

Transit Bus

89T Utility C18 MP

Utility Truck

HHD M

90T Utility C18 R

Utility Truck

HHD R

91T Utility C16-7 MP

Utility Truck

6-7

MHD M

92T Utility C16-7 R

Utility Truck

6-7

MHD R

93 T Utility C14-5 MP

Utility Truck

4-5

LHD M

94T Utility C12b-3 MP

Utility Truck

2b-3

LHD M

95T Utility C14-5 R

Utility Truck

4-5

LHD R

96T Utility C12b-3 R

Utility Truck

2b-3

LHD R

97T Utility C18 U

Utility Truck

HHD U

98T Utility C16-7 U

Utility Truck

6-7

MHD U

99T Utility C14-5 U

Utility Truck

4-5

LHD U

100T Utility C12b-3 U

Utility Truck

2b-3

LHD U

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Vehicle ID

Vehicle Application

Weight
Class

MOVES
source
TypelD

MOVES
regClassID

GEM Duty Cycle5™'3

101 Tractor DC C18 U

Yard Tractor

C8 DC LR

aLHD is light heavy-duty, MHD is medium heavy-duty, HHD is heavy heavy-duty, U is urban, R is regional, M is
multi-purpose, SC is sleeper cab, DC is day cab, HH is heavy haul, and LR is low roof

It should be noted that while the vehicles are defined throughout this document using several
different vehicle characteristics as well as vehicle performance metrics, we sometimes show the
vehicles grouped in different ways. This is due to the differences in categorization among
underlying data sources. For example, vehicles in MOVES are grouped differently than the GEM
regulatory subcategories. In most cases, we will show the results for the 101 HD TRUCS
vehicles in Figure 2-1, and include additional aggregation as applicable.

2.1.2 HD TRUCS Inputs

Inputs to the analysis were chosen based on our assessment of available literature, analysis,
engineering judgement, and other information about vehicles in the HD market, as described in
later Chapters. We presume that values from literature represent calendar year (CY), not model
year (MY), unless explicitly noted.

For example, baseline energy consumption is based largely on EPA's GEM model (see
Chapter 2.2.2), and the targets to determine the peak power requirement are based on the ANL
Autonomie model (see Chapter 2.4.1.2). Activity data is based on multiple data sources,
including National Renewable Energy Laboratory's (NREL) detailed FleetDNA data (see
Chapter 2.2.1). Vehicle sales estimates are generally based on EPA's MOVES and 2019
Compliance Division Production Verification (PV) data (see Chapter 2.2.3). Many of the cost
estimates and BEV and FCEV technical assumptions originated from ANL's Autonomiexvl and
BEnefit ANalysis (BEAN)XVU models used for DOE's Vehicle Technologies Office (VTO) and
Hydrogen and Fuel Cell Technologies Office (HFTO) Research and Development (R&D)
Benefits Analysis of 2022.17'18

We acknowledge that the ANL high-technology progress (low cost) and low-technology
progress (high cost) assumptions for medium- and heavy-duty vehicles represent technology
progress towards meeting DOE R&D goals and are not predictions of the future. DOE's high-
tech scenarios are intended to reflect values if all DOE technology targets are met by their target
dates, and DOE's low-tech scenarios reflect business as usual. As discussed in Chapter 1.3, there
is substantial federal investment through BIL and IRA to accelerate technology development and
reduce greenhouse gas emissions to meet challenging climate goals. Thus, we generally
considered a mid-range (average) of high-tech and low-tech values in HD TRUCS.

Assumptions were difficult to compare across analyses given that ZEVs are still nascent in
heavy-duty markets and actual data is limited. Most authors acknowledge there is uncertainty in

XV1 Autonomie is a vehicle system simulation tool used to assess the energy consumption, performance, and costs of
multiple advanced vehicle technologies.

xvu BEAN was developed to quantify the impact of individual vehicle component technologies on costs. ANL has
worked for years with industry stakeholders and other national laboratories to develop these tools.

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their projections. We applied our technical judgment in assessing relevant trends and used
engineering judgement where necessary.

2.2 HD Vehicle Benchmark Characteristics

HD TRUCS is designed to evaluate future HD ZEVs that can meet the energy demands of
many different types of HD ICE vehicles. To accomplish this, we have "benchmarked" HD
vehicle activity and typical rates of energy consumption at the axleXV111 for a wide range of vehicle
applications, weight classes, and duty cycles. We also collected data that is used to assign new
vehicle sales distributions for all HD TRUCS vehicle types.

Chapter 2.2.1 describes key vehicle activity metrics in HD TRUCS which includes annual and
daily vehicle miles traveled (VMT). Annual activity is primarily used for calculating operational
costs, and daily activityxlx is important for sizing ZEV components.

Chapter 2.2.2 describes the rate of energy consumption required of HD vehicles, including the
demand of PTOs and the recovered energy from regenerative braking.

HD TRUCS also includes the sales distribution of new HD vehicles, so that each of the 101
vehicle types represented in HD TRUCS can be assigned a fraction of new vehicle sales. This
allows us to create sales-weighted adoption rates for the ZEV technology packages. Chapter
2.2.3 describes how the sales weighting distributions were estimated for each HD TRUCS
vehicle category.

2.2.1 HD Vehicle Activity

In Chapter 2.2.1, we describe how we used time-related assumptions and VMT considerations
in HD TRUCS to establish performance benchmarks for HD ZEVs.

2.2.1.1 Time-Related Assumptions

2.2.1.1.1 Operating Days Per Year

HD TRUCS assumes that all vehicles, other than Recreational Vehicles (RVs) operate 250
days per year.19 We think this is a reasonable assumption as 250 days per year is equal to 50
weeks of 5 working days. RVs, however, are assumed to operate only 8 days per year (See
Chapter 2.2.1.2 for additional explanation.

2.2.1.1.2 Operating Hours Per Day

All vehicles in HD TRUCS are assumed to operate for 8 hours a day. Daily operating hours
are used to calculate the amount of energy needed per day for heating, ventilation, and air
conditioning (HVAC) based on the vehicles' power demand for HVAC, as described in Chapters
2.4.1.1.1 through 2.4.1.1.3, and 2.5.1.2.2.

xvm Chapter 2.2 generally describes HD vehicle energy consumption rates that do not include powertrain-specific
losses and energy demands. The powertrain-specific diesel, BEV, and FCEV losses and demands are described in
Chapters 2.3, 2.4, and 2.5, respectively.

X1X While ICE vehicles may not require daily refueling, BEVs and FCEVs in HD TRUCS are assumed to re-charge
or refuel every day; therefore, we size ZEV components to meet the daily energy and/or power demand that is
needed to accommodate a day of work.

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2.2.1.1.3 10-Year Assessment Period

Given the wide range of diversity in the trucking industry, HD TRUCS analyzes a vehicle's
operation during the first 10 years of ownership. We selected 10 years to include high mileage
years and to reflect changes in maintenance and repair costs over time, since vehicle use
(measured in VMT) and operating costs can change over the course of ownership and as a
vehicle ages. We assume that ICE engines will not need to be rebuilt and that battery packs and
fuel cell stacks do not need to be replaced during this timeframe.

2.2.1.2 Vehicle Miles Traveled (VMT)

Vehicle miles traveled, or VMT, is one way to consider heavy-duty vehicle activity. In HD
TRUCS, VMT is used to determine the daily and yearly use or operation of a vehicle, to size
BEV battery packs and other components, and to estimate infrastructure needs. We relied on
multiple sources to determine VMT applied in HD TRUCS for each vehicle. The sources for
daily VMT we considered were based on our assessment of on data availability. We have listed
them in order of publication date, the level of detail included in the data, and whether the data
was collected from in-use vehicles: NREL's FleetDNA20 database, a University of California,
Riverside21 (UC-Riverside) database, the Department of Transportation's Bureau of
Transportation Statistic's 2002 Vehicle Inventory and Use Survey22 (2002 VIUS), California Air
Resource Board (CARB) Large Entity Reporting23, or independent sources, as discussed
below.24'25 Values included in HD TRUCS by vehicle application are in Table 2-2.

For values available in the NREL and UC-Riverside databases, each vehicle was assigned a
50th percentile daily VMT and a 90th percentile daily VMT. The 50th percentile VMT is used to
calculate "operational VMT," as described in Chapter 2.2.1.2.2. The 90th percentile VMT is
assumed to be constant over the life of the vehicle (also referred to as "sizing VMT," as
described in Chapter 2.2.1.2.1).

Not all vehicle applications were reflected in the NREL or UC-Riverside databases. In these
instances, we used 2002 VIUS data. This data was reported as yearly VMT, which we divided by
the assumed 250 operating days per year to estimate the 50th percentile daily VMT. We then
applied factors to the VIUS 50th percentile daily VMT to estimate the 90th percentile daily VMT
for vehicles.xx

For the vehicle applications where VMT was not included in the NREL, UC-Riverside, or
2002 VIUS databases, we relied on independent sources to estimate daily VMT. For coach
buses, we used motorcoach census data for 2017.26 For RVs, we used average yearly VMT from
a 2009 Federal Highway Administration survey,27 divided by the average number of camping
trips per year from a Coleman Company, Inc. report,28 and multiplied by two (for two driving
days per camping trip). For school buses and shuttle buses, we used DOE's Alternative Fuels
Data Center (AFDC) information for Average Annual Vehicle Miles Traveled by Major Vehicle
Category.29

We divided the sleeper cab tractors into two configurations to represent a range of daily
mileage requirements. For the sleeper cab tractor with the longest daily operating range,
"79Tractor_SC_C18_R," we used MOVES data to set the 50th percentile operational VMT at

** See Miller, Neil. Memorandum to docket EPA-HQ-OAR-2022-0985. "Estimating 90th Percentile VMT for
Vehicles using 2002 VIUS Data". March 2023.

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420 miles and assumed 10 hours per day of operation at 55 mph to set the 90th percentile sizing
VMT at 550 miles. We relied on CARB's "Large Entity Fleet Reporting,"30 for the estimated
daily mileage of the shorter-range sleeper cab tractor, "78Tractor_SC_C18_MP." From the
percent of sleeper cabs in each row of data in Table 18 of the report, we calculated that the
median mileage for vehicles traveling less than or equal to 300 miles per day was 200 miles;
therefore, we used 200 miles to represent the 50th percentile operational VMT. We assumed the
sizing VMT for "78Tractor_SC_C18_MP" was 400 miles. We also used CARB's Large Entity
Fleet Reporting to determine that 28 percent of sleeper cab tractors could use the shorter
operating range.

Table 2-2 50th and 90th Percentile VMT in HD TRUCS

Vehicle ID

VMT
Source

50th Percentile

Operational
VMT (mi/day)

10 yr Average

Daily
Operational
VMT (mi/day)

10 yr Average

Annual
Operational
VMT (mi/yr)

90th Percentile
Sizing VMT
(mi/day)

01V Amb C14-5 MP

FleetDNA

7,493

02V Amb C12b-3 MP

FleetDNA

10,914

03V Amb C14-5 U

FleetDNA

8,631

04V Amb C12b-3 U

FleetDNA

8,783

05T Box C18 MP

2002 VIUS

14,578

06T Box C18 R

2002 VIUS

14,578

07T Box C16-7 MP

FleetDNA

8,800

08T Box C16-7 R

FleetDNA

8,800

09T Box C18 U

2002 VIUS

14,578

10T Box C16-7 U

FleetDNA

8,586

105

1 IT Box C12b-3 U

FleetDNA

16,022

12T Box C12b-3 R

FleetDNA

16,022

13T Box C12b-3 MP

FleetDNA

16,022

14T Box C14-5 U

FleetDNA

10,386

15T Box C14-5 R

FleetDNA

10,386

16T Box C14-5 MP

FleetDNA

10,386

17B Coach C18 R

Independent

158

140

34,904

293

18B Coach C18 MP

Independent

158

140

34,904

293

19C Mix C18 MP

UCR

19,736

20T Dump C18 U

2002 VIUS

8,835

111

21T Dump C18 MP

2002 VIUS

8,835

111

22T Dump C16-7 MP

FleetDNA

12,408

156

23 T Dump C18 U

2002 VIUS

8,835

111

24T Dump C16-7 U

FleetDNA

12,408

156

25T Fire C18 MP

2002 VIUS

8,835

111

26T Fire C18 U

2002 VIUS

8,835

111

27T Flat C16-7 MP

FleetDNA

8,800

28T Flat C16-7 R

FleetDNA

8,800

29T Flat C16-7 U

FleetDNA

8,800

30Tractor DC C18 MP

FleetDNA

18,152

136

31 Tractor DC C16-7 MP

FleetDNA

21,430

147

32Tractor DC C18 U

FleetDNA

18,152

136

33Tractor DC C16-7 U

FleetDNA

21,430

147

34T Ref C18 MP

FleetDNA

11,481

118

35T Ref C16-7 MP

2002 VIUS

20,674

118

36T Ref C18 U

FleetDNA

11,481

118

37T Ref C16-7 U

2002 VIUS

20,674

118

117

-------
Vehicle ID

VMT
Source

50th Percentile

Operational
VMT (mi/day)

10 yr Average

Daily
Operational
VMT (mi/day)

10 yr Average

Annual
Operational
VMT (mi/yr)

90th Percentile
Sizing VMT
(mi/day)

38RV C18 R

Independent

335

2,368

335

39RV C16-7 R

Independent

335

2,368

335

40RV C14-5 R

Independent

335

2,368

335

41RV C12b-3 R

Independent

335

2,368

335

42RV C18 MP

Independent

335

2,368

335

43RV C16-7 MP

Independent

335

2,368

335

44RV C14-5 MP

Independent

335

2,368

335

45RV C12b-3 MP

Independent

335

2,368

335

46B School C18 MP

Independent

10,602

47B School C16-7 MP

FleetDNA

11,288

48B School C14-5 MP

Independent

10,602

49B School C12b-3 MP

Independent

10,602

5OB School C18 U

Independent

10,602

5IB School C16-7 U

FleetDNA

11,288

52B School C14-5 U

Independent

10,602

53B School C12b-3 U

Independent

10,602

54B Shuttle C14-5 MP

Independent

118

104

26,001

150

55B Shuttle C12b-3 MP

Independent

118

104

26,001

150

56B Shuttle C14-5 U

Independent

118

104

26,001

150

57B Shuttle C12b-3 U

Independent

118

104

26,001

150

58B Shuttle C16-7 MP

Independent

118

104

26,001

150

59B Shuttle C16-7 U

Independent

118

104

26,001

150

60S Plow C16-7 MP

UCR

8,802

61S Plow C18 MP

UCR

9,772

62S Plow C16-7 U

UCR

8,802

63S Plow C18 U

UCR

9,772

64V Step C16-7 MP

FleetDNA

13,450

101

65V Step C14-5 MP

FleetDNA

8,416

66V Step C12b-3 MP

FleetDNA

13,107

67V Step C16-7 U

FleetDNA

13,450

101

68V Step C14-5 U

FleetDNA

8,416

69V Step C12b-3 U

FleetDNA

13,107

70S Sweep C16-7 U

2002 VIUS

11,132

7IT Tanker C18 R

2002 VIUS

11,397

72T Tanker C18 MP

2002 VIUS

11,397

73T Tanker C18 U

2002 VIUS

11,397

74T Tow C18 R

2002 VIUS

14,225

157

75T Tow C16-7 R

FleetDNA

12,387

157

76T Tow C18 U

2002 VIUS

14,225

157

77T Tow C16-7 U

FleetDNA

12,387

157

78Tractor SC C18 MP

Independent

200

187

46,636

400

79Tractor SC C18 R

Independent

420

392

97,935

550

80Tractor DC C18 HH

2002 VIUS

106

24,717

180

81 Tractor DC C17 R

FleetDNA

120

106

26,576

214

82Tractor DC C18 R

FleetDNA

216

191

47,634

349

83Tractor DC C17 U

FleetDNA

120

106

26,576

214

84Tractor DC C18 U

FleetDNA

216

191

47,634

349

85B Transit C18 MP

FleetDNA

136

120

29,976

203

86B Transit C16-7 MP

FleetDNA

17,690

219

87B Transit C18 U

FleetDNA

136

120

29,976

203

118

-------
Vehicle ID

VMT
Source

50th Percentile

Operational
VMT (mi/day)

10 yr Average

Daily
Operational
VMT (mi/day)

10 yr Average

Annual
Operational
VMT (mi/yr)

90th Percentile
Sizing VMT
(mi/day)

88B Transit C16-7 U

FleetDNA

17,690

219

89T Utility C18 MP

FleetDNA

5,895

90T Utility C18 R

FleetDNA

5,895

91T Utility C16-7 MP

2002 VIUS

10,867

92T Utility C16-7 R

2002 VIUS

10,867

93T Utility C14-5 MP

2002 VIUS

10,867

94T Utility C12b-3 MP

FleetDNA

4,973

95T Utility C14-5 R

2002 VIUS

10,867

96T Utility C12b-3 R

2002 VIUS

10,867

97T Utility C18 U

FleetDNA

5,895

98T Utility C16-7 U

2002 VIUS

10,867

99T Utility C14-5 U

2002 VIUS

10,867

100T Utility C12b-3 U

FleetDNA

4,973

101 Tractor DC C18 U

FleetDNA

14,080

127

2.2.1.2.1 Sizing VMT

The 90th percentile daily VMT was used to determine the storage capacity of the battery and
EVSE size requirements for BEVs, as well as onboard hydrogen storage capacity for the FCEVs.
We selected the 90th percentile VMT because we assumed that manufacturers would design their
ZEVs to meet most daily VMT needs, but not the most extreme operations. For example, BEVs
designed for 100th percentile daily VMT needs would be unnecessarily heavy and expensive for
most operations, which would limit their appeal in the market. For this analysis, we are assuming
that the vehicles between the 90th percentile and 100th percentile daily VMT would remain ICE
powered. The 90th percentile VMT is also referred to as the "sizing VMT."

2.2.1.2.2 Operational VMT

The 50th percentile daily VMT was used to estimate 10-year average daily or annual
operational VMT, which were then used to estimate costs associated with operating HD vehicles
such as the average annual fuel or electricity costs and maintenance and repair costs (see
Chapters 2.3.4, 2.4.4, and 2.5.3). The 50th percentile daily VMT was converted into a 10-year
average daily or annual operational VMT using the assumed operating time and assessment
period.

Use of HD vehicles varies over time, so we aligned assumptions in HD TRUCS with those in
MOVES for vehicle use (and therefore VMT) after the initial date of purchase, which is different
for different types of vehicles. In HD TRUCS, the VMT change over time was disaggregated for
two vehicle bins: (1) vocational vehicles and short-haul tractors, and (2) long-haul tractors.

Figure 2-1 shows how we varied annual VMT during the 10-year assessment period to account
for changes in use of the vehicle over time.

119

-------
fa0'9

a 0.8
¦ a

gi • Vocational Vehicles &

#
*

S 0.7 Short-Haul Tractors

^ • Long-Haul Tractors
0.6

2 4 6 8 10

Year

Figure 2-1 Change in VMT Over Time for HD Vehicles

We used the 50th percentile daily VMT as a proxy for the average amount of work done by a
vehicle during a normal workday. This was used to calculate the VMT for year 0, the first year of
operation, in HD TRUCS. For VMT data sources that only included annual VMT, we used the
250 days per year assumption described above to calculate a 50th percentile daily VMT, which
was used to calculate the VMT for year 0. See Equation 2-13 for change in VMT over time.

2.2.2 HD Vehicle Energy Consumption

In this section, we describe how we evaluated HD vehicle energy consumption requirements,
independent of the powertrain, to better understand how ZEVs could be designed to meet
technical performance requirements.

For each HD TRUCS vehicle type, we determined the baseline energy consumption
requirement that would be needed for ZEVs. We used EPA's GEM model to simulate road load
power requirements for various duty cycles over the default road load profiles to estimate work
performed by HD vehicles (as described in more detail in Chapter 2.2.2.1.1). ZEV baseline
energy includes the energy at the vehicle axle required to move the vehicle down the road (as
described in more detail in Chapter 2.2.2.1.2), the impact of regenerative brakingxxi (as
described in more detail below in Chapter 2.2.2.1.3), and PTO energy (as described in more
detail in 2.2.2.1.4). The resulting ZEV baseline energy requirements are shown in Table 2-3 for
each of the HD TRUCS vehicle types.

Other factors can impact energy consumption and power in a manner that may be different
among diesel vehicles, BEVs, and FCEVs. The energy demand for heating, ventilation, and air

XX1 Regenerative braking is the process of slowing down a moving vehicle by using the vehicle's electric motor as a
brake. This process allows the vehicle's electric motor to generate electricity which is then stored in the vehicle's
battery and increases the net efficiency of the vehicle.

120

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conditioning (HVAC) is discussed in 2.2.2.2. Additional powertrain-specific impacts on energy
consumption and power are described in Chapters 2.3.3, 2.4.1.1, and 2.5.1.2.

Table 2-3 Energy Requirements of HDVs

Vehicle ID

ZEV Baseline Energy Requirements

Axle (kWh/mi)

Regen Braking
(kWh/mi)

PTO (kWh/mi)

ZEV Baseline
Energy (kWh/mi)

01V Amb C14-5 MP

0.86

-0.08

0.00

0.78

02V Amb C12b-3 MP

0.86

-0.08

0.00

0.78

03V Amb C14-5 U

0.82

-0.13

0.00

0.68

04V Amb C12b-3 U

0.82

-0.13

0.00

0.68

05T Box C18 MP

2.07

-0.23

0.00

1.84

06T Box C18 R

2.07

-0.09

0.00

1.97

07T Box C16-7 MP

1.36

-0.14

0.00

1.23

08T Box C16-7 R

1.45

-0.06

0.00

1.39

09T Box C18 U

2.07

-0.37

0.00

1.70

10T Box C16-7 U

1.31

-0.22

0.00

1.09

1 IT Box C12b-3 U

0.82

-0.13

0.00

0.68

12T Box C12b-3 R

0.91

-0.03

0.00

0.88

13T Box C12b-3 MP

0.86

-0.08

0.00

0.78

14T Box C14-5 U

0.82

-0.13

0.00

0.68

15T Box C14-5 R

0.91

-0.03

0.00

0.88

16T Box C14-5 MP

0.86

-0.08

0.00

0.78

17B Coach C18 R

1.91

-0.09

0.00

1.82

18B Coach C18 MP

1.91

-0.09

0.00

1.82

19C Mix C18 MP

2.02

-0.36

0.46

2.12

20T Dump C18 U

2.07

-0.37

0.11

1.80

21T Dump C18 MP

2.07

-0.23

0.09

1.93

22T Dump C16-7 MP

1.36

-0.14

0.07

1.30

23 T Dump C18 U

2.07

-0.37

0.11

1.80

24T Dump C16-7 U

1.31

-0.22

0.08

1.16

25T Fire C18 MP

2.07

-0.23

0.14

1.98

26T Fire C18 U

2.07

-0.37

0.18

1.87

27T Flat C16-7 MP

1.36

-0.14

0.00

1.23

28T Flat C16-7 R

1.45

-0.06

0.00

1.39

29T Flat C16-7 U

1.31

-0.22

0.00

1.09

30Tractor DC C18 MP

2.20

-0.14

0.00

2.07

31 Tractor DC C16-7 MP

1.79

-0.09

0.00

1.69

32Tractor DC C18 U

2.20

-0.14

0.00

2.07

3 3 Tractor DC C16-7 U

1.79

-0.09

0.00

1.69

34T Ref C18 MP

2.01

-0.36

0.31

1.96

35T Ref C16-7 MP

2.01

-0.36

0.56

2.20

36T Ref C18 U

2.01

-0.36

0.31

1.96

37T Ref C16-7 U

2.01

-0.36

0.56

2.20

38RV C18 R

1.36

-0.05

0.00

1.31

39RV C16-7 R

1.45

-0.06

0.00

1.39

40RV C14-5 R

0.91

-0.03

0.00

0.88

41RV C12b-3 R

0.91

-0.03

0.00

0.88

42RV C18 MP

1.36

-0.05

0.00

1.31

43RV C16-7 MP

1.36

-0.14

0.00

1.23

44RV C14-5 MP

0.86

-0.08

0.00

0.78

45RV C12b-3 MP

0.86

-0.08

0.00

0.78

46B School C18 MP

1.22

-0.21

0.00

1.02

121

-------
Vehicle ID

ZEV Baseline Energy Requirements

Axle (kWh/mi)

Regen Braking
(kWh/mi)

PTO (kWh/mi)

ZEV Baseline
Energy (kWh/mi)

47B School C16-7 MP

1.22

-0.21

0.00

1.02

48B School C14-5 MP

0.86

-0.08

0.00

0.78

49B School C12b-3 MP

0.86

-0.08

0.00

0.78

5OB School C18 U

1.22

-0.21

0.00

1.02

5 IB School C16-7 U

1.22

-0.21

0.00

1.02

52B School C14-5 U

0.82

-0.13

0.00

0.68

53B School C12b-3 U

0.82

-0.13

0.00

0.68

54B Shuttle C14-5 MP

0.86

-0.08

0.00

0.78

55B Shuttle C12b-3 MP

0.86

-0.08

0.00

0.78

56B Shuttle C14-5 U

0.82

-0.13

0.00

0.68

57B Shuttle C12b-3 U

0.82

-0.13

0.00

0.68

58B Shuttle C16-7 MP

1.36

-0.14

0.00

1.23

59B Shuttle C16-7 U

1.31

-0.22

0.00

1.09

60S Plow C16-7 MP

1.36

-0.14

0.16

1.38

61S Plow C18 MP

2.07

-0.23

0.11

1.95

62S Plow C16-7 U

1.31

-0.22

0.17

1.26

63 S Plow C18 U

2.07

-0.37

0.14

1.83

64V Step C16-7 MP

1.36

-0.14

0.00

1.23

65V Step C14-5 MP

0.86

-0.08

0.00

0.78

66V Step C12b-3 MP

0.86

-0.08

0.00

0.78

67V Step C16-7 U

1.31

-0.22

0.00

1.09

68V Step C14-5 U

0.82

-0.13

0.00

0.68

69V Step C12b-3 U

0.82

-0.13

0.00

0.68

70S Sweep C16-7 U

1.31

-0.22

0.15

1.24

71T Tanker C18 R

2.07

-0.09

0.11

2.09

72T Tanker C18 MP

2.07

-0.23

0.13

1.97

73T Tanker C18 U

2.07

-0.37

0.16

1.86

74T Tow C18 R

2.07

-0.09

0.09

2.06

75T Tow C16-7 R

1.45

-0.06

0.07

1.46

76T Tow C18 U

2.07

-0.37

0.12

1.82

77T Tow C16-7 U

1.31

-0.22

0.08

1.16

78Tractor SC C18 MP

2.17

-0.07

0.00

2.10

79Tractor SC C18 R

2.17

-0.07

0.00

2.10

80Tractor DC C18 HH

3.27

-0.23

0.00

3.04

81 Tractor DC C17 R

1.79

-0.09

0.00

1.69

82Tractor DC C18 R

2.20

-0.14

0.00

2.07

83Tractor DC C17 U

1.79

-0.09

0.00

1.69

84Tractor DC C18 U

2.20

-0.14

0.00

2.07

85B Transit C18 MP

1.99

-0.36

0.00

1.63

86B Transit C16-7 MP

1.99

-0.36

0.00

1.63

87B Transit C18 U

1.99

-0.36

0.00

1.63

88B Transit C16-7 U

1.99

-0.36

0.00

1.63

89T Utility C18 MP

2.07

-0.23

0.14

1.98

90T Utility C18 R

2.07

-0.09

0.13

2.10

91T Utility C16-7 MP

1.36

-0.14

0.10

1.33

92T Utility C16-7 R

1.45

-0.06

0.10

1.49

93 T Utility C14-5 MP

0.86

-0.08

0.07

0.85

94T Utility C12b-3 MP

0.86

-0.08

0.06

0.84

95T Utility C14-5 R

0.91

-0.03

0.07

0.95

96T Utility C12b-3 R

0.91

-0.03

0.07

0.95

97T Utility C18 U

2.07

-0.37

0.18

1.87

122

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Vehicle ID

ZEV Baseline Energy Requirements

Axle (kWh/mi)

Regen Braking
(kWh/mi)

PTO (kWh/mi)

ZEV Baseline
Energy (kWh/mi)

98T Utility C16-7 U

1.31

-0.22

0.12

1.20

99T Utility C14-5 U

0.82

-0.13

0.08

0.77

100T Utility C12b-3 U

0.82

-0.13

0.07

0.75

101 Tractor DC C18 U

2.20

-0.14

0.00

2.07

2.2.2.1 ZEVBaseline Energy Consumption

ZEV baseline energy is assumed to be the minimum energy required for the HD vehicle to
perform its required work. Here, ZEV baseline energy includes the energy at the axle required to
move the vehicle, impacts of regenerative braking (for vehicles with an electric motor), and the
additional energy required from power take-off (PTO) units, if applicable.

We used EPA's GEM model to simulate road load power requirements for various duty
cycles over the default road load profiles to estimate work performed by HD vehicles. GEM does
this by modeling physical characteristics of a vehicle that include vehicle mass, frontal area, tire
rolling resistance, tire size, gear ratio, accessory loads, as well as reductions in power demand for
weight reduction and other technologies that reduce demand from the vehicle. This analysis was
performed using engine fuel maps created by EPA when setting the MY 2027 and later HD GHG
Phase 2 vehicle standards31 and default GEM input values for the physical vehicle characteristics
for each of the regulatory subcategories from EPA's HD GHG Phase 2 rulemaking (see the
existing standards in Table 2-83, for tractors, and in Table 2-84 for vocational vehicles for a list
of the regulatory subcategories, including the vocational optional chassis subcategories).^11 The
GEM input values also include default mechanical and electrical accessory loads, (see Table 2-8
and Table 2-9).xxiii

We used a tool developed in-house for hybrid vehicles to calculate a weighted percent of
energy recovery due to regenerative braking.XX1V This tool is like GEM in that it models physical
vehicle properties over the default GEM road load profiles and uses the GEM weighting for each
regulatory subcategory to calculate weighted energy recovered from the GEM duty cycles. We
used the same default GEM inputs for this tool as we used for the GEM simulations to maintain
consistency in our calculations.

We incorporated PTO calculations into the ZEV baseline energy because they are the key
aspect of work from some HD vehicles. In HD TRUCS, PTO is converted into kilowatt-hour
(kWh) per mile (mi) using the operational hours and operational VMT for vehicles that have a
PTO unit. We recognize that the presentation of PTO in terms of kWh/mi may suggest that all
PTO loads are consumed while the vehicle is moving, but this is not the case for several vehicle

xxu Note that GEM values are sometime applicable to a broader grouping of regulatory subcategories, so we will
generally show GEM values at the regulatory subcategory grouping level that is appropriate. The vocational optional
chassis subcategories are assigned a vocational vehicle services class and duty cycle for GEM simulations, as
described in 40 CFR. 1037.105(h).

xxm Note that the HVAC loads are subsequently removed to determine ZEV baseline energy consumption because
HVAC loads differ among different powertrain technologies. See Chapter 2.2.2.1.2 for more detail on the removal
of HVAC loads for ZEV baseline energy.

XX1V Miller, Neil. Memorandum to docket EPA-HQ-OAR-2022-0985. "Simple Hybrid Model". March 2023.

123

-------
types. Nonetheless, PTO is presented in terms of kWh/mi to help facilitate different calculations
inHD TRUCS.

The total ZEV baseline energy is the summation of axle, regenerative braking, and PTO load
energies, as shown in Table 2-3. Detailed descriptions of these values as well as inputs to GEM
are discussed in Chapters 2.2.2.1.1-2.2.2.1,4.xxv

2.2.2.1.1 GEM Inputs

Table 2-4 through Table 2-7 show the engine, drivetrain, tire, and other default GEM
parameters. Any GEM parameters not listed have a value of zero.

Table 2-4 Model Year 2027 GEM Engine Parameters

Regulatory
Subcategory

Engine File Name

Engine
Power

C8 SC HR

EnginesVEPA 2027 D SC GENERIC 455 TCA SIM GEMv351.csv

455

C8 SC MR

EnginesVEPA 2027 D SC GENERIC 455 TCA SIM GEMv351.csv

455

C8 SC LR

EnginesVEPA 2027 D SC GENERIC 455 TCA SIM GEMv351.csv

455

C8 DC HR

EnginesVEPA 2027 D SC GENERIC 455 TCA SIM GEMv351.csv

455

C8 DC MR

EnginesVEPA 2027 D SC GENERIC 455 TCA SIM GEMv351.csv

455

C8 DC LR

EnginesVEPA 2027 D SC GENERIC 455 TCA SIM GEMv351.csv

455

C7 DC HR

EnginesVEPA 2027 D GENERIC 350 TCA SIM GEMv351.csv

350

C7 DC MR

EngmesVEPA 2027 D GENERIC 350 TCA SIM GEMv351.csv

350

C7 DC LR

EngmesVEPA 2027 D GENERIC 350 TCA SIM GEMv351.csv

350

C8 HH

EngmesVEPA 2018 D GENERIC 600 TCA SIM GEMv351.csv

600

HHD R

EngmesVEPA 2027 D Voc GENERIC 455 TCA SIM GEMv351.csv

455

HHD M

EngmesVEPA 2027 D Voc GENERIC 350 TCA SIM GEMv351.csv

350

HHD U

EngmesVEPA 2027 D Voc GENERIC 350 TCA SIM GEMv351.csv

350

MHD R

EngmesVEPA 2027 D GENERIC 270 TCA SIM GEMv351.csv

270

MHD M

EngmesVEPA 2027 D GENERIC 270 TCA SIM GEMv351.csv

270

MHD U

EngmesVEPA 2027 D GENERIC 270 TCA SIM GEMv351.csv

270

LHD R

EngmesVEPA 2027 D GENERIC 200 TCA SIM GEMv351.csv

200

LHD M

EngmesVEPA 2027 D GENERIC 200 TCA SIM GEMv351.csv

200

LHD U

EngmesVEPA 2027 D GENERIC 200 TCA SIM GEMv351.csv

200

EngmesVEPA 2027 D GENERIC 270 TCA SIM GEMv351.csv

270

School Bus

EngmesVEPA 2027 D GENERIC 270 TCA SIM GEMv351.csv

270

Coach Bus

EngmesVEPA 2027 D Voc GENERIC 350 TCA SIM GEMv351.csv

350

Emergency

EngmesVEPA 2027 D Voc GENERIC 350 TCA SIM GEMv351.csv

350

Mixer

EngmesVEPA 2027 D Voc GENERIC 350 TCA SIM GEMv351.csv

350

Transit Bus

EngmesVEPA 2027 D Voc GENERIC 350 TCA SIM GEMv351.csv

350

Refuse Truck

EngmesVEPA 2027 D Voc GENERIC 350 TCA SIM GEMv351.csv

350

Table 2-5 Model Year 2027 GEM Drivetrain Parameters

Regulatory
Subcategory

Transmission File Name

Drive Axle
Config

Drive Axle
Ratio

C8 SC HR

TransmissionsVEPA MT 10 C78 4490 hires.csv

6X4

3.16

C8 SC MR

TransmissionsVEPA MT 10 C78 4490 hires.csv

6X4

3.16

C8 SC LR

TransmissionsVEPA MT 10 C78 4490 hires.csv

6X4

3.16

^ See also Miller, Neil. Memorandum to docket EPA-HQ-OAR-2022-0985. "Gem Inputs and Results". March
2023.

124

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Regulatory
Subcategory

Transmission File Name

Drive Axle
Config

Drive Axle
Ratio

C8 DC HR

TransmissionsYEPA MT 10 C78 4490 hires.csv

6X4

3.21

C8 DC MR

TransmissionsYEPA MT 10 C78 4490 hires.csv

6X4

3.21

C8 DC LR

TransmissionsYEPA MT 10 C78 4490 hires.csv

6X4

3.21

C7 DC HR

TransmissionsYEPA MT 10 C78 4490 hires.csv

4X2

3.21

C7 DC MR

TransmissionsYEPA MT 10 C78 4490 hires.csv

4X2

3.21

C7 DC LR

TransmissionsYEPA MT 10 C78 4490 hires.csv

4X2

3.21

C8 HH

TransmissionsYEPA MT 18 HH hires, csv

6X4

3.70

HHD R

TransmissionsYEPA MT 10 HHD 4490 hires, csv

6X4

3.76

HHD M

TransmissionsYEPA AT 6 HHD.csv

6X4

4.33

HHD U

TransmissionsYEPA AT 5 HHD 1020 hires, csv

6X4

5.29

MHD R

TransmissionsYEPA AT 6 MHD.csv

4X2

5.50

MHD M

TransmissionsYEPA AT 6 MHD.csv

4X2

5.29

MHD U

TransmissionsYEPA AT 5 MHD 803 hires.csv

4X2

5.29

LHD R

TransmissionsYEPA AT 6 LHD.csv

4X2

4.33

LHD M

TransmissionsYEPA AT 6 LHD.csv

4X2

4.56

LHD U

TransmissionsYEPA AT 5 LHD 803 hires.csv

4X2

4.56

TransmissionsYEPA AT 6 MHD.csv

4X2

5.50

School Bus

TransmissionsYEPA AT 5 MHD 803 hires.csv

4X2

5.29

Coach Bus

TransmissionsYEPA AT 6 HHDBus.csv

4X2

4.33

Emergency

TransmissionsYEPA AT 5 HHD 1020 hires.csv

6X4

5.29

Mixer

TransmissionsYEPA AT 5 HHDMixer.csv

6X4

5.29

Transit Bus

TransmissionsYEPA AT 5 HHD 1020 hires.csv

4X2

5.29

Refuse Truck

TransmissionsYEPA AT 5 HHD 1020 hires.csv

6X4

5.29

Table 2-6 Model Year 2027 GEM Tire Parameters

Regulatory
Subcategory

Aerodynamic
Drag Area

Steer Axle

Rolling
Resistance

Drive Axle 1

Rolling
Resistance

Drive Axle 2

Rolling
Resistance

Drive
Axle Tire
Size

C8 SC HR

5.26

5.6

5.8

512

C8 SC MR

6.21

5.8

6.2

512

C8 SC LR

5.08

5.8

6.2

512

C8 DC HR

5.67

5.6

5.8

512

C8 DC MR

6.21

5.8

6.2

512

C8 DC LR

5.12

5.8

6.2

512

C7 DC HR

5.67

5.6

5.8

512

C7 DC MR

6.21

5.8

6.2

512

C7 DC LR

5.12

5.8

6.2

512

C8 HH

5.8

6.2

512

HHD R

7.7

496

HHD M

7.7

496

HHD U

7.7

496

MHD R

7.7

517

MHD M

7.7

557

MHD U

7.7

557

LHD R

7.7

670

LHD M

7.7

670

LHD U

7.7

660

5.8

517

School Bus

5.9

6.3

557

Coach Bus

5.8

496

125

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Regulatory
Subcategory

Aerodynamic
Drag Area

Steer Axle

Rolling
Resistance

Drive Axle 1

Rolling
Resistance

Drive Axle 2

Rolling
Resistance

Drive
Axle Tire
Size

Emergency

6.4

8.1

496

Mixer

6.7

7.2

496

Transit Bus

6.7

6.8

517

Refuse Truck

6.7

6.8

496

Table 2-7 Model Year 2027 GEM Other Parameters

Regulatory
Subcategory

Idle
Speed

Weight
Reduction

Intelligent
Controls

Accessory
Load

Extended Idle
Reduction

Tire
Pressure
System

Other

C8 SC HR

600

0.8

0.5

5.5

C8 SC MR

600

0.8

0.5

5.5

C8 SC LR

600

0.8

0.5

5.5

C8 DC HR

600

0.8

0.5

5.7

C8 DC MR

600

0.8

0.5

5.7

C8 DC LR

600

0.8

0.5

5.7

C7 DC HR

650

0.8

0.5

5.1

C7 DC MR

650

0.8

0.5

5.1

C7 DC LR

650

0.8

0.5

5.1

C8 HH

600

0.8

0.5

9.5

HHD R

600

0.0

HHD M

650

0.0

HHD U

650

0.0

MHD R

750

0.0

MHD M

750

0.0

MHD U

750

0.0

LHD R

750

0.0

LHD M

750

0.0

LHD U

750

0.0

750

0.0

School Bus

750

0.0

Coach Bus

650

0.0

Emergency

650

0.0

Mixer

650

0.0

Transit Bus

650

0.0

Refuse Truck

650

0.0

Characteristics such as mass, rotational inertia, coefficient of drag, tire rolling resistance,
payload, and electrical and mechanical accessory power (to account for additional loads related
to accessories such as lights, radio, HVAC, and cooling fans) were all default values from GEM
for each weight class and vehicle type. Table 2-8 contains values for tractors, and Table 2-9
contains values for vocational vehicles. Additional details about model defaults can be found in
the GEM documentation.32

126

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Table 2-8 GEM Tractor Inputs

Regulatory Class

Characteristic

Roof Height

High
Roof

Mid
Roof

Low Roof

C8 DC

Total Weight (kg)

31,297

29,529

29,710

Coefficient of Drag (mA2)

5.67

6.21

5.12

Rolling Resistance (kg/ton)

6.2

Rotational Mass (kg)

794

Payload (tons)

Electrical Acc Power (kW)

1200

Mechanical Acc Power (kW)

2300

C8 SC

Total Weight (kg)

31,978

30,277

30,390

Coefficient of Drag(mA2)

5.26

6.21

5.08

Rolling Resistance (kg/ton)

6.2

Rotational Mass (kg)

794

Payload (tons)

Electrical Acc Power (kW)

1200

Mechanical Acc Power (kW)

2300

C7 DC

Total Weight (kg)

22,679

20,910

21,091

Coefficient of Drag(mA2)

5.67

6.21

5.12

Rolling Resistance (kg/ton)

6.2

Rotational Mass (kg)

340

Payload (tons)

12.5

Electrical Acc Power (kW)

1200

Mechanical Acc Power (kW)

2300

C7 SC

Total Weight (kg)

22,679

20,910

21,091

Coefficient of Drag(mA2)

5.26

6.21

5.08

Rolling Resistance (kg/ton)

6.2

Rotational Mass (kg)

340

Payload (tons)

12.5

Electrical Acc Power (kW)

1200

Mechanical Acc Power (kW)

2300

C8 HH

Total Weight (kg)

53750

Coefficient of Drag(mA2)

6.21

Rolling Resistance (kg/ton)

6.2

Rotational Mass (kg)

794

Payload (tons)

Electrical Acc Power (kW)

1200

Mechanical Acc Power (kW)

2300

Table 2-9 GEM Vocational Vehicle Inputs

Regulatory Class

Total
Weight
(kg)

Coefficient
of Drag
(mA2)

Rolling
Resistance
(kg/ton)

Rotational

Mass (kg)

Payload
(tons)

Electrical
Acc Power
(kW)

Mechanical
Acc Power
(kW)

HHD

19,051

6.86

7.7

794

7.50

1200

2300

MHD

11,408

5.40

7.7

340

5.60

900

1600

LHD

7,257

3.40

7.7

340

2.85

500

1000

Emergency Vehicles

19,051

6.86

7.7

794

7.50

1200

2300

Cement Mixers

19,051

6.86

7.7

794

7.50

1200

2300

Refuse Trucks

19,051

6.86

7.7

794

7.50

1200

2300

Coach Buses

19,051

6.86

7.7

794

7.50

1200

2300

127

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Regulatory Class

Total
Weight
(kg)

Coefficient
of Drag
(mA2)

Rolling
Resistance
(kg/ton)

Rotational

Mass (kg)

Pay load
(tons)

Electrical
Acc Power
(kW)

Mechanical
Acc Power
(kW)

Transit Buses

19,051

6.86

7.7

794

7.50

1200

2300

Motor Homes

11,408

5.40

7.7

340

5.60

900

1600

School Buses

11,408

5.40

7.7

340

5.60

900

1600

2.2.2.1.2 GEM Energy Consumption at the Axle

To determine energy consumption per mile, we first calculated work performed, or energy
consumed, at the axle (kWh) and CO2 emissions (grams) for each duty cycle in Table 2-10; this
was determined for the constant cruise at 55 and 65 miles per hour (MPH) cycles as well as the
transient cycle.

We also removed the air conditioning compressor portion of the HVAC loads from axle work
because HVAC loads differ between different powertrain technologies such as ICE, BEV, and
FCEV. Therefore, we considered HVAC loads separately from the ZEV baseline energy
consumption that is used for ZEVs. The energy consumption at the axle, as shown in Table 2-10,
was determined by subtracting this HVAC power demand, weighted by GEM duty cycle, from
the GEM output. The power consumption of the HVAC load during the duty cycle that we
removed was 1.0 kilowatt (kW) for LHD and MHD vehicles and 1.5 kW for remainder of the
vehicles based on the mechanical accessory loads developed for HD GHG Phase 2 version of
GEM.33 The HVAC load is calculated assuming that the HVAC system is operating at a constant
load during the entire duty cycle.

Table 2-10 Model Year 2027 GEM Axle Work and CO2 Emissions (HVAC load has been removed)

Regulatory
Subcategory

Cruise 55 MPH

Cruise 65 MPH

Transient

Cycle

Axle Work

Grams of

Axle Work

Grams of

Axle Pos Work

Grams of

(kWh)

CO2

(kWh)

CO2

(kWh)

CO2

C8 SC HR

23.5

13855

27.2

15655

8.2

6124

C8 SC MR

25.4

14881

30.0

17174

7.9

5994

C8 SC LR

23.3

13792

27.1

15661

7.8

5947

C8 DC HR

24.0

14711

28.0

16826

8.0

6286

C8 DC MR

25.3

15353

29.8

17818

7.7

6116

C8 DC LR

23.1

14276

27.0

16311

7.7

6079

C7 DC HR

20.0

12662

24.01

14915

5.9

5169

C7 DC MR

21.1

13290

25.9

15907

5.6

4967

C7 DC LR

19.1

12198

23.0

14381

5.6

4926

C8 HH

34.0

21058

37.6

23359

13.4

9982

HHD R

23.5

16537

29.2

20266

5.5

5046

HHD M

23.5

17704

29.0

21596

5.5

5748

HHD U

23.5

21563

28.4

27897

5.5

5736

MHD R

16.7

14321

21.1

17409

3.4

4016

MHD M

16.7

14447

21.1

17465

3.4

4026

MHD U

16.7

14980

21.2

18443

3.4

4043

LHD R

10.5

9626

13.3

11514

2.1

2763

LHD M

10.5

9836

13.4

11868

2.1

2808

LHD U

10.5

10513

13.3

12974

2.1

2820

15.5

13506

19.9

16534

3.2

3854

School Bus

15.6

14247

20.1

17729

3.1

3794

Coach Bus

21.5

15859

27.0

19539

5.1

5423

128

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Regulatory
Subcategory

Cruise 55 MPH

Cruise 65 MPH

Transient

Cycle

Axle Work

Grams of

Axle Work

Grams of

Axle Pos Work

Grams of

(kWh)

CO2

(kWh)

CO2

(kWh)

CO2

Emergency

23.4

21493

28.3

17834

5.4

5722

Mixer

22.9

21149

27.8

27525

5.4

5651

Transit Bus

22.6

20628

27.4

26948

5.3

5495

Refuse Truck

22.6

20971

27.5

27363

5.3

5614

The values for work performed during each duty cycle were then divided by the distance of
each duty cycle to determine the energy demand per mile. The distance and duration of each duty
cycle are listed in Table 2-11.

Table 2-11 GEM Duty Cycle Distance and Time

GEM Duty Cycle

Distance (miles)

Time (s)

Transient

2.84

668

55 Cruise

13.43

879

65 Cruise

13.43

743.8

Energy required per mile was then weighted by the applicable GEM weighting factor for each
test cycle and respective regulatory class to adjust consumption based on GEM distance
weighting (by duty cycle) and time weighting (by percent at idle) factors, as well as average
speed during non-idle cycles, as shown in Table 2-12. (Note that the regulatory categories that
use the same weight factor are aggregated in the table.)

Table 2-12 GEM Test Cycle Weighting Factors and Average Speed

Regulatory Subcategory

Distance-weighted Factor

Time-weighted Factor

Average
speed
(MPH)

Transient

55
Cruise

65
Cruise

Drive
idle (%)

Parked
idle (%)

Non-idle

(%)

Sleeper Cab

Day Cab

Heavy-haul tractors

Vocational - Regional

28.41

Vocational - Multi-Purpose (2b-7)

23.18

Vocational - Multi-Purpose (8)

23.27

Vocational - Urban (2b-7)

16.25

Vocational - Urban (8)

16.51

The values were summed to calculate the energy consumption by regulatory class. The
resulting values for weighted energy consumption per mile at the axle are shown in Table 2-13.
As described above, HVAC loads have been removed, and neither PTO loads nor regenerative
braking benefits are included in Table 2-13.

Table 2-13 GEM Weighted Energy Consumption per Mile

Regulatory Subcategory

Weighted Axle Work per Mile (kWh/mi)

C8 SC HR

2.18

C8 SC MR

2.38

C8 SC LR

2.17

C8 DC HR

2.29

129

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Regulatory Subcategory

Weighted Axle Work per Mile (kWh/mi)

C8 DC MR

2.37

C8 DC LR

2.20

C7 DC HR

1.87

C7 DC MR

1.95

C7 DC LR

1.79

C8 HH

3.27

HHD R

2.07

HHD M

2.07

HHD U

2.07

MHD R

1.45

MHD M

1.36

MHD U

1.31

LHD R

0.91

LHD M

0.86

LHD U

0.82

1.36

School Bus

1.22

Coach Bus

1.91

Emergency

2.06

Mixer

2.02

Transit Bus

1.99

Refuse Truck

2.01

2.2.2.1.3 Regenerative Braking

Regenerative braking is utilized on BEVs and FCEVs, but the amount of potential energy
recovery is dependent on the vehicle properties and drive cycle. The details for calculating our
projections for regenerative (sometimes referred to as "regen") braking energy can be found in
Chapter 2.7.1. In summary, to calculate percent energy recovery available, we estimated the
braking energy and divided by the total tractive energy (i.e., the energy required to move the
vehicle) for each drive cycle and then weighted the results using the respective GEM test cycle
weighting factors from Table 2-12. The results are in Table 2-14.

Table 2-14 Percent Energy Recovered from Regenerative Braking

Regulatory
Subcategory

Regen (%)

C8 SC

3.29

C8 DC

3.21

C7 DC

5.26

C8 HH

7.07

HHD R

4.52

HHD M

11.07

HHD U

17.92

MHD R

3.88

MHD M

10.06

MHD U

16.85

LHD R

3.79

LHD M

9.83

LHD U

16.47

3.88

130

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Regulatory
Subcategory

Regen (%)

School Bus

16.85

Coach Bus

4.52

Emergency

17.92

Mixer

17.92

Transit Bus

17.92

Refuse Truck

17.92

These values were then multiplied by the weighted energy consumption per mile (Table 2-13)
to get energy recovered per mile from regenerative braking. Results are in Table 2-15.

Table 2-15 Energy Recovered per Mile from Regenerative Braking

Regulatory
Subcategory

Regen
(kWh/mile)

C8 SC

0.07

C8 DC

0.14

C7 DC

0.09

C8 HH

0.23

HHD R

0.09

HHD M

0.23

HHD U

0.37

MHD R

0.06

MHD M

0.14

MHD U

0.22

LHD R

0.03

LHD M

0.08

LHD U

0.13

0.05

School Bus

0.21

Coach Bus

0.09

Emergency

0.37

Mixer

0.36

Transit Bus

0.36

Refuse Truck

0.36

Note that GEM outputs are by vehicle type. Energy recovered from regenerative braking per
mile for each regulatory subcategory was then applied to the applicable 101 vehicle types in HD
TRUCS. Chapters 2.3, 2.4 and 2.5 discuss how electrical energy and fuel consumption per mile
are attributed to the 101 HD TRUCS vehicle types for ICE vehicles, BEVs, and FCEVs,
respectively.

2.2.2.1.4 Power Take Off (PTO)

Some vocational vehicles selected as representative of the heavy-duty industry have
attachments that perform work, typically by powering a hydraulic pump, which are powered by
PTOs. Information on in-use PTO energy demand cycles is limited. NREL published two papers
describing investigative work into PTO usage and energy consumption.34'35 These studies,
however, were limited to electric utility vehicles, such as bucket trucks and material handlers. To
account for PTO usage in HD TRUCS, we chose to rely on a table described in California's

131

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Diesel Tax Fuel Regulations, specifically in Regulation 1432, "Other Nontaxable Uses of Diesel
Fuel in a Motor Vehicle."36 The table for Regulation 1432 covers a wider range of vehicles
beyond the electric utility vehicles in the previously mentioned NREL studies. This table
contains "safe-harbor" percentages that are presumed amounts of diesel fuel used for "auxiliary
equipment" operated from the same fuel tank as the motor vehicle. In California, a person may
apply for a fuel tax refund for diesel fuel that is not used to operate a motor vehicle upon a
highway in California.37 We used this table to estimate PTO energy use as a function of total fuel
consumed by vehicle type, as shown in Table 2-16 and Table 2-17.

In HD TRUCS, the vehicle applications with PTO energy consumption estimates include
boom (utility) truck, cement mixer, dump truck, fire truck, garbage truck (refuse handler),
snowplow, (street) sweeper, tanker truck, and wrecker (tow truck). While the list of applications
from Regulation 1432 (Table 2-16) covers a wider variety of vehicles, we believe that the HD
TRUCS vehicles cover a reasonable range of PTO energy consumption because the values
associated with the "Types" below that are in HD TRUCS represent typical energy consumption
values due to PTO. The vehicle selection process and energy usage estimation are described in
Chapters 2.1.1 and 2.2.2 The assignment within HD TRUCS is shown in Table 2-17.

Table 2-16 PTO Energy Use as a Function of Total Energy Consumed38

Type

PTO Percent (%)

None

Boom truck/block boom

Bulk feed truck

Car carrier with hydraulic winch

Carpet cleaning van

Cement mixer

Cement pumper

Distribution truck (hot asphalt)

Dump trailer

Dump truck

Fire truck

Garbage truck

Leaf truck

Lime spreader

Line truck with digger, derrick or aerial lift

Log truck with self-loader

Mobile crane

Pneumatic tank truck

Refrigeration truck

Salt spreader (dump with spreader)

Seeder truck

Semi-wrecker

Service truck with jack hammer/drill

Sewer cleaning truck/jet

Snow plow

Spray truck

Super sucker (port-o-let trucks)

Sweeper truck

T ank transport

T ank truck

Truck with hydraulic winch

132

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Type

PTO Percent (%)

Transfer trailer

Wrecker

Other Auxiliary Equipment

Table 2-17 PTO Assignment in HD TRUCS

Vehicle ID

PTO Percent (%)

19C Mix C18 MP

25%

20T Dump C18 U

15%

21T Dump C18 MP

15%

22T Dump C16-7 MP

15%

23T Dump C18 U

15%

24T Dump C16-7 U

15%

25T Fire C18 MP

25%

26T Fire C18 U

25%

34T Ref C18 MP

35%

35T Ref C16-7 MP

35%

36T Ref C18 U

35%

37T Ref C16-7 U

35%

60S Plow C16-7 MP

15%

61S Plow C18 MP

15%

62S Plow C16-7 U

15%

63S Plow C18 U

15%

70S Sweep C16-7 U

20%

7IT Tanker C18 R

15%

72T Tanker C18 MP

15%

73T Tanker C18 U

15%

74T Tow C18 R

15%

75T Tow C16-7 R

15%

76T Tow C18 U

15%

77T Tow C16-7 U

15%

89T Utility C18 MP

15%

90T Utility C18 R

15%

91T Utility C16-7 MP

15%

92T Utility C16-7 R

15%

93T Utility C14-5 MP

15%

94T Utility C12b-3 MP

15%

95T Utility C14-5 R

15%

96T Utility C12b-3 R

15%

97T Utility C18 U

15%

98T Utility C16-7 U

15%

99T Utility C14-5 U

15%

100T Utility C12b-3 U

15%

Table 2-16 shows the PTO energy as a percent of total energy consumed. We assumed the
fuel is consumed while operating a diesel-powered vehicle on an annual basis. To incorporate the
value into the ZEV baseline energy consumption on a kWh/mi basis, we converted the fuel
consumption of vehicles listed in Table 2-17 from MPG into annual diesel fuel consumption
using 250 operating days in a year. Since GEM does not include PTO of these vehicles, the PTO
fuel consumption is the PTO percent multiplied by the annual GEM fuel consumption. This is

133

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then converted back to a daily value by dividing by 250 operating days per year, and then to an
axle and per-mile value by applying the diesel energy content and losses from the diesel
powertrain system. A detailed description of PTO calculations can be found in Chapter 2.3.3.

2.2.2.2 Heating, Ventilation, and Air Conditioning (HVAC) Energy Consumption

Heating, ventilation, and air conditioning (HVAC) energy requirements vary by vehicle type,
vocation, and duty cycle. The HVAC energy required to heat and cool interior cabins is
considered separately from the baseline energy, since these energy loads are not required year-
round or in all regions of the country and most vehicles are equipped with air conditioning
(A/C). Nearly all commercial vehicles are equipped with heat and basic ventilation. In ICE
vehicles, traditional cabin heating makes use of excess thermal energy produced by the main
ICE. This is the only source of cabin heating for many vehicle types. Additionally, on ICE
vehicles, cabin A/C uses a mechanical refrigerant compressor that is engine belt driven. A/C
utilizes a thermodynamic cycle to move thermal energy from the cabin to the ambient air outside
the vehicle, cooling and dehumidifying the cabin. Compressors can also be driven by an electric
motor.

Energy consumption associated with vehicle heating and cooling is dependent on passenger
comfort requirements, cabin size and materials, ambient air temperature, relative humidity,
number of occupants, number of door openings and closings, and the HVAC system technology
type and efficiency.

Cabin heating utilizing engine waste heat requires electrical power to run the controls and
blower motors. A/C operation adds mechanical load on the engine to run the compressor and
requires electric power to operate the HVAC blower motor.

As described in Chapter 2.2.2.1.2, although GEM already includes HVAC load in its power
consumption, because of the unique and different nature of BEVs and FCEVs, this incorporated
load is removed from the calculated GEM energy consumption at the axle for ZEV baseline
energy. Then, a separate HVAC calculation is performed to calculate the "axle" level HVAC
consumption of BEVs and FCEVs irrespective of the energy source (i.e., the battery or
hydrogen). We describe how HVAC is considered for BEVs and FCEVs in Chapters 2.4.1.1.1
and 2.5.1.2.2. For diesel vehicles, the GEM results (including the HVAC energy demand) are
used.

2.2.3 HP Vehicle Sales

Sales percentages for each vehicle application were calculated using MY 2019 Compliance
Division (CD) Production Verification (PV) dataXXV1'16 and MOVESxxvu new vehicle sales data
using the definition of model year as specified in 40 CFR 1037.801. We did this by applying
market shares in the 2019 CD PV data to the new vehicle sales data in MOVES by
sourceTypelD and regClassID. We first aggregated the MY 2019 CD PV data into 25 of the

xxvl EPA's Compliance Division, in the Office of Transportation and Air Quality (OTAQ), collects PV data from
vehicle original equipment manufacturers (OEMs) to comply with regulations in 40 CFR 1037.250 to be used in the
calculations for generating emissions credits in 40 CFR 1037.705.

xxvn HD TRUCS uses MOVES3.R1, which is a version of EPA's MOtor Vehicle Emission Simulator, a state-of-the-
science emission modeling system that estimates tailpipe emissions for mobile sources at the national, county, and
project level for criteria air pollutants, greenhouse gases, and air toxics.

134

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allowable combinations of sourceTypelDs and regClassIDs for HD vehicles in MOVES and
totaled the sales for each combination, as shown in Table 2-18 below. We then apportioned the
Class 7 Sleeper Cab sales to the Class 8 Sleeper Cab sales as Class 7 Sleeper Cabs are not a
separate regulatory subcategory.

Table 2-18 MY 2019 CD PV Data by MOVES ID

MOVES sourceTypelD

MOVES regClassID

2019 CD PV Sales

1,476

4,337

1,987

17,620

1,128

2,055

4,768

108,995

34,341

18,471

22,361

135,932

512

614

661

59,617

630

3,532

8,070

71,437

115,881

We found that the PV data was missing 12 of the allowable combinations of sourceTypelDs
and regClassIDs for HD vehicles in MOVES. We added these missing combinations to the PV
data, with sales of one vehicle for each missing combination. See Table 2-19 for a summary of
missing segments.

Table 2-19 MOVES IDs Missing from PV Data

MOVES sourceTypelD

MOVES regClassID

2019 CD PV Sales

N/A

135

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53

N/A

Using the data in Table 2-18, we were able to calculate the percent of sales by the allowable
sourceTypelD and regClassID combinations in the 2019 CD PV data. We then divided the
percent sales in each sourceTypelD and regClassID by the number of the 101 HD TRUCS
vehicle applications attributed to each allowable sourceTypelD and regClassID combination in
the 2019 CD PV data. This yielded the percent of sales to apply to MOVES new vehicle sales by
sourceTypelD and regClassID. Table 2-20 has a summary of our results.

Table 2-20 Redistribution of 2019 CD PV Data to MOVES New Vehicle Sales

MOVES
source-
TypelD

MOVES

2019 CD

% of 2019 CD
PV Sales for
MOVES IDs

# HD TRUCS

Vehicle
Applications

Percent of 2019 MOVES
New Vehicle Sales in Each

regClassID

PV Sales

HD TRUCS Vehicle
Application

100 %

100%

100 %

100%

100 %

100%

1,476

100 %

50%

100 %

100%

100 %

100%

100 %

33.3 %

4,337

100 %

100%

100 %

100%

100 %

50%

100 %

50%

1,987

100 %

50%

17,620

100 %

50%

1,128

100 %

50%

2,055

100 %

50%

4,768

4.19%

2.1 %

108,995

95.81 %

19.2%

34,341

65.02 %

32.5 %

18,471

34.98%

22,361

14.08%

135,932

85.60 %

6.6 %

512

0.32 %

0.2 %

614

1.01 %

0.5 %

661

1.09%

0.5%

59,617

97.91 %

6.5 %

100 %

33.3 %

100 %

100%

100 %

100%

100 %

100%

100 %

50%

100 %

50%

630

100 %

50%

3,532

100 %

50%

8,070

100 %

25%

71,437

99.89%

25%

136

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MOVES
source-
TypelD

MOVES

2019 CD

% of 2019 CD
PV Sales for
MOVES IDs

# HD TRUCS

Vehicle
Applications

Percent of 2019 MOVES
New Vehicle Sales in Each

regClassID

PV Sales

HD TRUCS Vehicle
Application

0.11 %

0.1 %

100 %

0.0 %

115,881

100 %

50%

We used the MOVES new vehicle sales from MY 2019 to keep consistent with the MY 2019
CD PV data. The number of sales in each sourceTypelD and regClassID are in Table 2-21.
Glider sales for Combination Long Haul and Combination Short Haul were added to Class 8
Combination Long Haul and Class 8 Combination Short Haul, respectively.xxvm

Table 2-21 MY 2019 MOVES New Vehicle Sales

MOVES

2019 MOVES New

sourceTypelD

regClassID

Vehicle Sales

6,035

408

17,990

1,255

3,743

1,664

25,081

1,957

571

3,327

249,783

153,187

78,547

41,406

11,016

6,756

3,464

1,826

18,578

18,951

9,835

5,937

21,700

56,894

108,627

xxvm Glider vehicles are not represented in HD TRUCS as they have no powertrain to model energy consumption
from and there is no GEM regulatory subcategory for them. We chose to add them to the sales totals as these
vehicles will be fitted with a powertrain and typically used onroad.

137

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We then multiplied the 2019 MOVES sourceTypelD and regClassID new vehicle sales by the
appropriate percent of sales in each HD TRUCS vehicle application to obtain the number of sales
in each HD TRUCS vehicle application. The number of sales for each HD TRUCS vehicle
application was then entered into HD TRUCS. Sales fractions were calculated for each
sourceTypelD and regClassID category by dividing the HD TRUCS vehicle application sales by
the total number of sales and are shown in Table 2-22, along with the calculated sales numbers.

Table 2-22 HD TRUCS Vehicle Sales

MOVES

2019 MOVES

Percent of 2019 MOVES

TRUCS
Sales

Vehicle ID

sourceType
ID

regClassID

New Vehicles
Sales

New Vehicle Sales in Each
HD TRUCS Vehicle

Application

01V Amb C14-5 MP

153,187

7,654

02V Amb C12b-3 MP

249,783

5,234

03V Amb C14-5 U

153,187

7,654

04V Amb C12b-3 U

249,783

5,234

05T Box C18 MP

41,406

2,703

06T Box C18 R

1,826

100%

1,826

07T Box C16-7 MP

78,547

5,530

08T Box C16-7 R

3,464

100%

3,464

09T Box C18 U

41,406

2,703

10T Box C16-7 U

78,547

5,530

1 IT Box C12b-3 U

249,783

19%

47,863

12T Box C12b-3 R

249,783

19%

47,863

13T Box C12b-3 MP

249,783

19%

47,863

14T Box C14-5 U

153,187

7,654

15T Box C14-5 R

153,187

7,654

16T Box C14-5 MP

153,187

7,654

17B Coach C18 R

17,990

50%

8,995

18B Coach C18 MP

17,990

50%

8,995

19C Mix C18 MP

41,406

449

20T Dump C18 U

41,406

2,703

21T Dump C18 MP

41,406

2,703

22T Dump C16-7 MP

78,547

5,172

23T Dump C18 U

41,406

2,703

24T Dump C16-7 U

78,547

5,172

25T Fire C18 MP

41,406

209

26T Fire C18 U

41,406

209

27T Flat C16-7 MP

78,547

5,172

28T Flat C16-7 R

78,547

5,172

29T Flat C16-7 U

78,547

5,172

30Tractor DC C18 MP

56,894

21%

11,367

31 Tractor DC C16-7 MP

21,700

25%

5,425

32Tractor DC C18 U

56,894

30%

17,308

33Tractor DC C16-7 U

21,700

25%

5,425

34T Ref C18 MP

3,327

50%

1,663

35T Ref C16-7 MP

571

50%

285

36T Ref C18 U

3,327

50%

1,663

37T Ref C16-7 U

571

50%

285

38RV C18 R

5,937

50%

2,969

138

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MOVES

2019 MOVES

Percent of 2019 MOVES

TRUCS
Sales

Vehicle ID

sourceType
ID

regClassID

New Vehicles
Sales

New Vehicle Sales in Each
HD TRUCS Vehicle

Application

39RV C16-7 R

9,835

50%

4,918

40RV C14-5 R

18,951

50%

9,475

41RV C12b-3 R

18,578

50%

9,289

42RV C18 MP

5,937

50%

2,969

43RV C16-7 MP

9,835

50%

4,918

44RV C14-5 MP

18,951

50%

9,475

45RV C12b-3 MP

18,578

50%

9,289

46B School C18 MP

1,957

50%

979

47B School C16-7 MP

25,081

50%

12,540

48B School C14-5 MP

1,664

50%

832

49B School C12b-3 MP

50%

5OB School C18 U

1,957

50%

979

5IB School C16-7 U

25,081

50%

12,540

52B School C14-5 U

1,664

50%

832

53B School C12b-3 U

50%

54B Shuttle C14-5 MP

1,255

100%

1,255

55B Shuttle C12b-3 MP

100%

56B Shuttle C14-5 U

6,035

100%

6,035

57B Shuttle C12b-3 U

100%

58B Shuttle C16-7 MP

33%

59B Shuttle C16-7 U

408

100%

408

60S Plow C16-7 MP

78,547

5,172

61S Plow C18 MP

41,406

2,703

62S Plow C16-7 U

78,547

5,172

63S Plow C18 U

41,406

2,703

64V Step C16-7 MP

78,547

127

65V Step C14-5 MP

153,187

33%

49,805

66V Step C12b-3 MP

11,016

33%

3,672

67V Step C16-7 U

78,547

127

68V Step C14-5 U

153,187

33%

49,805

69V Step C12b-3 U

11,016

33%

3,672

70S Sweep C16-7 U

78,547

5,172

7IT Tanker C18 R

41,406

2,703

72T Tanker C18 MP

41,406

2,703

73T Tanker C18 U

41,406

2,703

74T Tow C18 R

41,406

2,703

75T Tow C16-7 R

78,547

5,172

76T Tow C18 U

41,406

2,703

77T Tow C16-7 U

78,547

5,172

78Tractor SC C18 MP

108,627

50%

30,416

79Tractor SC C18 R

108,627

50%

78,212

80Tractor DC C18 HH

41,406

21%

11,367

81 Tractor DC C17 R

21,700

25%

5,425

82Tractor DC C18 R

56,894

21%

11,367

83 Tractor DC C17 U

21,700

25%

5,425

84Tractor DC C18 U

56,894

4,000

85B Transit C18 MP

3,743

100%

3,743

86B Transit C16-7 MP

33%

87B Transit C18 U

100%

88B Transit C16-7 U

33%

139

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MOVES

2019 MOVES

Percent of 2019 MOVES

TRUCS
Sales

Vehicle ID

sourceType
ID

regClassID

New Vehicles
Sales

New Vehicle Sales in Each
HD TRUCS Vehicle

Application

89T Utility C18 MP

41,406

2,703

90T Utility C18 R

41,406

2,703

91T Utility C16-7 MP

78,547

5,172

92T Utility C16-7 R

78,547

5,172

93T Utility C14-5 MP

153,187

7,654

94T Utility C12b-3 MP

249,783

19%

47,863

95T Utility C14-5 R

6,756

100%

6,756

96T Utility C12b-3 R

11,016

33%

3,672

97T Utility C18 U

41,406

2,703

98T Utility C16-7 U

78,547

5,172

99T Utility C14-5 U

153,187

7,654

100T Utility C12b-3 U

249,783

19%

47,863

101 Tractor DC C18 U

56,894

2.3 ICE Vehicle Technology

As mentioned above, a goal of EPA's analysis is to ensure that we evaluate ZEVs that can
perform the same work as comparable ICE vehicles. HD TRUCS only considers powertrain or
propulsion technologies and operational costs that are the incremental differences between a
ZEV and a comparable ICE vehicle; this section does not reflect total manufacturing or total
operating costs.

Chapter 2.2 introduced how we estimated the baseline amount of energy required to move
each benchmark HD vehicle type, considering regenerative braking and additional work required
for PTO operations, independent of the powertrain. Chapter 2.3 explains how we applied the
values in Chapter 2.2 to diesel vehicles and then considered HVAC and other powertrain-specific
energy consumption. First, we defined the vehicle size and powertrain for each of the 101
vehicles in HD TRUCS, and then estimated upfront DMC of the ICE vehicle powertrain
components that are different from ZEV components. Then, we projected fuel use, diesel engine
fluid (DEF) consumption, and maintenance and repair costs for each diesel vehicle type on an
annual basis and annualized the operational costs over a 10-year period.

2.3.1 ICE Vehicle Attributes

To understand the physical size of current heavy-duty trucks, we looked at basic powertrain
properties and performance criteria of 76 existing diesel vehicles (see Chapter 1) to find averages
of the wheelbase and frame depth based on weight class and vehicle type. Note that the 76
existing vehicles cover all 101 vehicle types used in HD TRUCS because some of the 76
vehicles are further differentiated by duty cycles. Frame depth was not a widely reported value.
We were only able to find data on Class 8 trucks that suggested about 10 inches of frame depth.
Based on this data, we assumed that vehicles in a lower weight class would have frame depths of
smaller values due to the lower payload capacity. Based on this assumption, we assigned a frame
depth of 10 inches to Class 6-8 vehicles, a frame depth of 8 inches to Class 4-5 vehicles, and a
frame depth of 6 inches to Class 2b-3 vehicles. We then applied the results of this analysis to the
101 vehicles in HD TRUCS based on the same division of weight class and vehicle type used for
averaging the benchmark vehicles. The results of this analysis are in Table 2-23.

140

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Powertrain component weights were also determined from the 76 benchmark vehicles. The
averages of the total weight of the engine, transmission, fuel, and DEF were calculated by
vehicle type and weight class. These averages were then applied to the appropriate HD TRUCS
vehicles. The results of this analysis are in Table 2-23.

Table 2-23 Benchmark ICE Vehicle Dimensions and Weight

Vehicle ID

Vehicle
Wheelbase fin]

Vehicle Frame
Depth (in)

ICE Powertrain
Weight fkgl

01V Amb C14-5 MP

141

788

02V Amb C12b-3 MP

148

462

03V Amb C14-5 U

141

788

04V Amb C12b-3 U

148

462

05T Box C18 MP

125

1370

06T Box C18 R

125

1370

07T Box C16-7 MP

146

879

08T Box C16-7 R

146

879

09T Box C18 U

125

1370

10T Box C16-7 U

146

879

1 IT Box C12b-3 U

141

462

12T Box C12b-3 R

141

462

13T Box C12b-3 MP

141

462

14T Box C14-5 U

148

788

15T Box C14-5 R

148

788

16T Box C14-5 MP

148

788

17B Coach C18 R

315

2302

18B Coach C18 MP

315

2302

19C Mix C18 MP

143

1805

20T Dump C18 U

125

1370

21T Dump C18 MP

125

1370

22T Dump C16-7 MP

146

879

23 T Dump C18 U

125

1370

24T Dump C16-7 U

146

879

25T Fire C18 MP

125

1370

26T Fire C18 U

125

1370

27T Flat C16-7 MP

146

879

28T Flat C16-7 R

146

879

29T Flat C16-7 U

146

879

30Tractor DC C18 MP

143

1805

31 Tractor DC C16-7 MP

143

1805

32Tractor DC C18 U

143

1805

3 3 Tractor DC C16-7 U

143

1805

34T Ref C18 MP

173

1762

35T Ref C16-7 MP

146

879

36T Ref C18 U

173

1762

37T Ref C16-7 U

146

879

38RV C18 R

148

879

39RV C16-7 R

169

593

40RV C14-5 R

141

528

41RV C12b-3 R

139

462

42RV C18 MP

148

879

43RV C16-7 MP

169

593

44RV C14-5 MP

141

528

141

-------
Vehicle ID

Vehicle
Wheelbase fin]

Vehicle Frame
Depth (in)

ICE Powertrain
Weight fkgl

45RV C12b-3 MP

139

462

46B School C18 MP

145

1209

47B School C16-7 MP

169

1209

48B School C14-5 MP

139

536

49B School C12b-3 MP

138

536

5OB School C18 U

145

1209

5 IB School C16-7 U

169

1209

52B School C14-5 U

139

536

53B School C12b-3 U

139

536

54B Shuttle C14-5 MP

139

788

55B Shuttle C12b-3 MP

133

572

56B Shuttle C14-5 U

139

788

57B Shuttle C12b-3 U

133

572

58B Shuttle C16-7 MP

169

1209

59B Shuttle C16-7 U

169

1209

60S Plow C16-7 MP

146

879

61S Plow C18 MP

125

1370

62S Plow C16-7 U

146

879

63 S Plow C18 U

125

1370

64V Step C16-7 MP

158

593

65V Step C14-5 MP

134

788

66V Step C12b-3 MP

133

462

67V Step C16-7 U

158

593

68V Step C14-5 U

134

593

69V Step C12b-3 U

133

462

70S Sweep C16-7 U

169

1209

71T Tanker C18 R

125

1370

72T Tanker C18 MP

125

1370

73T Tanker C18 U

125

1370

74T Tow C18 R

125

1370

75T Tow C16-7 R

146

879

76T Tow C18 U

125

1370

77T Tow C16-7 U

146

879

78Tractor SC C18 MP

143

1805

79Tractor SC C18 R

143

1805

80Tractor DC C18 HH

143

1805

81 Tractor DC C17 R

143

1805

82Tractor DC C18 R

143

1805

83Tractor DC C17 U

143

1805

84Tractor DC C18 U

143

1805

85B Transit C18 MP

202

1217

86B Transit C16-7 MP

169

790

87B Transit C18 U

202

1217

88B Transit C16-7 U

169

790

89T Utility C18 MP

125

1370

90T Utility C18 R

125

1370

91T Utility C16-7 MP

146

879

92T Utility C16-7 R

146

879

93 T Utility C14-5 MP

148

788

94T Utility C12b-3 MP

149

775

95T Utility C14-5 R

148

788

96T Utility C12b-3 R

149

775

142

-------
Vehicle ID

Vehicle
Wheelbase fin]

Vehicle Frame
Depth (in)

ICE Powertrain
Weight fkgl

97T Utility C18 U

125

1370

98T Utility C16-7 U

146

879

99T Utility C14-5 U

148

788

100T Utility C12b-3 U

149

775

101 Tractor DC C18 U

116

1036

2.3.2 Diesel Vehicle Components and Upfront Costs

The following ICE vehicle components were included in the cost analysis as primary
components of the ICE powertrain: engine, transmission/gearbox, starter, mechanical
accessories, torque converter/clutch, final drive, and generator/alternator. The cost of each
component was added to the component cost used in EPA's technology package to meet the new
NOx emissions standards in the proposed 2027 Heavy-Duty Low NOx Rule.39 This method was
used to estimate a total ICE powertrain cost per vehicle type .

The cost of the engine and transmission/gearbox are two of the most expensive powertrain
components in an ICE HD vehicle. The cost of the diesel engine is calculated as a function of
engine power. To calculate engine costs, we used data from a report by Islam et al. from ANL
where cost of the engine increases with the power output of the engine, as shown in Figure 2-2.40
It should be noted the aftertreatment cost is incorporated as a part of the engine cost. The power
requirements for each vehicle are based on the power requirements that were used to determine
GEM energy consumption, as shown in Table 2-24. We used the transmission costs from
Autonomie Output in BEAN41 and mapped the costs to similar vehicles in HD TRUCS. The
remainder of the powertrain cost, including starter, mechanical accessories, torque
converter/clutch, final drive, and generator/alternator, are binned according to Table 2-25. These
costs are not a major portion of the costs of the ICE powertrain; therefore, we made simplifying
assumptions based on what is available in Autonomie. Costs of all components used for ICEs are
shown in Table 2-26 for MY 2032.

3
2.5

8 1-5

0.5
0

Figure 2-2 Direct Manufacturing Cost of a Diesel Engine as a Function of Engine Power57

x10

baseline engine cost
emission device cost "

250 300 350

Engine Power (kW)

143

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Table 2-24 Engine Power used as GEM Inputs and to Determine Engine Cost

Vehicle ID

GEM Engine Power (kW)

01V Amb C14-5 MP

149

02V Amb C12b-3 MP

149

03V Amb C14-5 U

149

04V Amb C12b-3 U

149

05T Box C18 MP

339

06T Box C18 R

339

07T Box C16-7 MP

201

08T Box C16-7 R

201

09T Box C18 U

261

10T Box C16-7 U

201

1 IT Box C12b-3 U

149

12T Box C12b-3 R

149

13T Box C12b-3 MP

149

14T Box C14-5 U

149

15T Box C14-5 R

149

16T Box C14-5 MP

149

17B Coach C18 R

261

18B Coach C18 MP

261

19C Mix C18 MP

261

20T Dump C18 U

339

21T Dump C18 MP

339

22T Dump C16-7 MP

201

23 T Dump C18 U

261

24T Dump C16-7 U

201

25T Fire C18 MP

339

26T Fire C18 U

261

27T Flat C16-7 MP

201

28T Flat C16-7 R

201

29T Flat C16-7 U

201

30Tractor DC C18 MP

339

31 Tractor DC C16-7 MP

261

32Tractor DC C18 U

339

3 3 Tractor DC C16-7 U

261

34T Ref C18 MP

261

35T Ref C16-7 MP

201

36T Ref C18 U

261

37T Ref C16-7 U

201

38RV C18 R

201

39RV C16-7 R

201

40RV C14-5 R

149

41RV C12b-3 R

149

42RV C18 MP

201

43RV C16-7 MP

201

44RV C14-5 MP

149

45RV C12b-3 MP

149

46B School C18 MP

201

47B School C16-7 MP

201

48B School C14-5 MP

149

49B School C12b-3 MP

149

5OB School C18 U

201

5 IB School C16-7 U

201

144

-------
Vehicle ID

GEM Engine Power (kW)

52B School C14-5 U

149

53B School C12b-3 U

149

54B Shuttle C14-5 MP

149

55B Shuttle C12b-3 MP

149

56B Shuttle C14-5 U

149

57B Shuttle C12b-3 U

149

58B Shuttle C16-7 MP

201

59B Shuttle C16-7 U

201

60S Plow C16-7 MP

201

61S Plow C18 MP

339

62S Plow C16-7 U

201

63 S Plow C18 U

261

64V Step C16-7 MP

201

65V Step C14-5 MP

149

66V Step C12b-3 MP

149

67V Step C16-7 U

201

68V Step C14-5 U

149

69V Step C12b-3 U

149

70S Sweep C16-7 U

201

71T Tanker C18 R

339

72T Tanker C18 MP

261

73T Tanker C18 U

261

74T Tow C18 R

339

75T Tow C16-7 R

201

76T Tow C18 U

261

77T Tow C16-7 U

201

78Tractor SC C18 MP

339

79Tractor SC C18 R

339

80Tractor DC C18 HH

447

81 Tractor DC C17 R

261

82Tractor DC C18 R

339

83Tractor DC C17 U

261

84Tractor DC C18 U

339

85B Transit C18 MP

261

86B Transit C16-7 MP

201

87B Transit C18 U

261

88B Transit C16-7 U

201

89T Utility C18 MP

339

90T Utility C18 R

339

91T Utility C16-7 MP

201

92T Utility C16-7 R

201

93 T Utility C14-5 MP

149

94T Utility C12b-3 MP

149

95T Utility C14-5 R

149

96T Utility C12b-3 R

149

97T Utility C18 U

261

98T Utility C16-7 U

201

99T Utility C14-5 U

149

100T Utility C12b-3 U

149

101 Tractor DC C18 U

339

145

-------
Table 2-25 Binned Direct Manufacturing Costs for ICE Powertrain Components for MY 2032 (2021$)

Vehicle

Starter

Torque

Mech

Generator

2027 Rule Cost

Final Drive Cost ($/unit)

Class

Cost

Converter

Acc

Cost

($/unit)

Clutch
Cost
($/unit)

Cost
($/unit)

($/unit)

2b-5

158

533

2346

1431

1581

6-7

158

533

2346

1430

1581

316

413

2346

174

2330

1581

Table 2-26 ICE Powertrain (PT) Direct Manufacturing Cost (DMC) for MY 2032 (2021$)

Vehicle ID

Engine

Cost
($/unit)

Gearbox
($/unit)

2027
Rule
Cost
($/unit)

Starter

Cost
($/unit)

Mech
Acc.
Cost
($/unit)

Torque
Converter
Clutch
Cost
($/unit)

Final
Drive
Cost
($/unit)

Generator
Cost
($/unit)

ICE
PT
DMC
($/unit)

01V Amb C14-5 MP

$15,812

$6,183

$1,431

$158

$2,346

$533

$1,581

$70

$28,115

02V Amb C12b-3 MP

$15,812

$4,877

$1,431

$158

$2,346

$533

$1,581

$70

$26,808

03V Amb C14-5 U

$15,812

$6,183

$1,431

$158

$2,346

$533

$1,581

$70

$28,115

04V Amb C12b-3 U

$15,812

$4,877

$1,431

$158

$2,346

$533

$1,581

$70

$26,808

05T Box C18 MP

$38,186

$11,097

$2,330

$316

$2,346

$413

$1,581

$70

$56,339

06T Box C18 R

$38,186

$11,097

$2,330

$316

$2,346

$413

$1,581

$70

$56,339

07T Box C16-7 MP

$18,974

$5,265

$1,430

$158

$2,346

$533

$1,581

$70

$30,358

08T Box C16-7 R

$18,974

$5,265

$1,430

$158

$2,346

$533

$1,581

$70

$30,358

09T Box C18 U

$30,082

$11,097

$2,330

$316

$2,346

$413

$1,581

$70

$48,235

10T Box C16-7 U

$18,974

$5,265

$1,430

$158

$2,346

$533

$1,581

$70

$30,358

1 IT Box C12b-3 U

$15,812

$4,429

$1,431

$158

$2,346

$533

$1,581

$70

$26,360

12T Box C12b-3 R

$15,812

$4,429

$1,431

$158

$2,346

$533

$1,581

$70

$26,360

13T Box C12b-3 MP

$15,812

$4,429

$1,431

$158

$2,346

$533

$1,581

$70

$26,360

14T Box C14-5 U

$15,812

$4,521

$1,431

$158

$2,346

$533

$1,581

$70

$26,453

15T Box C14-5 R

$15,812

$4,521

$1,431

$158

$2,346

$533

$1,581

$70

$26,453

16T Box C14-5 MP

$15,812

$4,521

$1,431

$158

$2,346

$533

$1,581

$70

$26,453

17B Coach C18 R

$30,082

$5,762

$2,330

$316

$2,346

$413

$1,581

$70

$42,900

18B Coach C18 MP

$30,082

$5,762

$2,330

$316

$2,346

$413

$1,581

$70

$42,900

19C Mix C18 MP

$30,082

$11,097

$2,330

$316

$2,346

$413

$1,581

$70

$48,235

20T Dump C18 U

$38,186

$11,097

$2,330

$316

$2,346

$413

$1,581

$70

$56,339

21T Dump C18 MP

$38,186

$11,097

$2,330

$316

$2,346

$413

$1,581

$70

$56,339

22T Dump C16-7 MP

$18,974

$5,092

$1,430

$158

$2,346

$533

$1,581

$70

$30,185

23T Dump C18 U

$30,082

$11,097

$2,330

$316

$2,346

$413

$1,581

$70

$48,235

24T Dump C16-7 U

$18,974

$5,092

$1,430

$158

$2,346

$533

$1,581

$70

$30,185

25T Fire C18 MP

$38,186

$11,097

$2,330

$316

$2,346

$413

$1,581

$70

$56,339

26T Fire C18 U

$30,082

$11,097

$2,330

$316

$2,346

$413

$1,581

$70

$48,235

27T Flat C16-7 MP

$18,974

$5,092

$1,430

$158

$2,346

$533

$1,581

$70

$30,185

28T Flat C16-7 R

$18,974

$5,092

$1,430

$158

$2,346

$533

$1,581

$70

$30,185

29T Flat C16-7 U

$18,974

$5,092

$1,430

$158

$2,346

$533

$1,581

$70

$30,185

30Tractor DC C18 MP

$38,186

$10,743

$2,330

$316

$2,346

$413

$3,162

$174

$57,671

31 Tractor DC C16-7 MP

$30,082

$7,025

$1,430

$316

$2,346

$533

$3,162

$174

$45,070

32Tractor DC C18 U

$38,186

$9,213

$2,330

$316

$2,346

$413

$3,162

$174

$56,140

33Tractor DC C16-7 U

$30,082

$7,025

$1,430

$316

$2,346

$533

$3,162

$174

$45,070

34T Ref C18 MP

$30,082

$8,244

$2,330

$316

$2,346

$413

$1,581

$70

$45,383

35T Ref C16-7 MP

$18,974

$5,092

$1,430

$158

$2,346

$533

$1,581

$70

$30,185

146

-------
Vehicle ID

Engine

Cost
($/unit)

Gearbox
($/unit)

2027
Rule
Cost
($/unit)

Starter

Cost
($/unit)

Mech
Acc.
Cost
($/unit)

Torque
Converter
Clutch
Cost
($/unit)

Final
Drive
Cost
($/unit)

Generator
Cost
($/unit)

ICE
PT
DMC
($/unit)

36T Ref C18 U

$30,082

$8,244

$2,330

$316

$2,346

$413

$1,581

$70

$45,383

37T Ref C16-7 U

$18,974

$5,092

$1,430

$158

$2,346

$533

$1,581

$70

$30,185

38RV C18 R

$18,974

$5,762

$2,330

$316

$2,346

$413

$1,581

$70

$31,792

39RV C16-7 R

$18,974

$5,169

$1,430

$158

$2,346

$533

$1,581

$70

$30,262

40RV C14-5 R

$15,812

$3,946

$1,431

$158

$2,346

$533

$1,581

$70

$25,878

41RV C12b-3 R

$15,812

$5,225

$1,431

$158

$2,346

$533

$1,581

$70

$27,156

42RV C18 MP

$18,974

$5,762

$2,330

$316

$2,346

$413

$1,581

$70

$31,792

43RV C16-7 MP

$18,974

$5,169

$1,430

$158

$2,346

$533

$1,581

$70

$30,262

44RV C14-5 MP

$15,812

$3,946

$1,431

$158

$2,346

$533

$1,581

$70

$25,878

45RV C12b-3 MP

$15,812

$5,225

$1,431

$158

$2,346

$533

$1,581

$70

$27,156

46B School C18 MP

$18,974

$5,762

$2,330

$316

$2,346

$413

$1,581

$70

$31,792

47B School C16-7 MP

$18,974

$5,169

$1,430

$158

$2,346

$533

$1,581

$70

$30,262

48B School C14-5 MP

$15,812

$3,946

$1,431

$158

$2,346

$533

$1,581

$70

$25,878

49B School C12b-3 MP

$15,812

$5,225

$1,431

$158

$2,346

$533

$1,581

$70

$27,156

5OB School C18 U

$18,974

$5,762

$2,330

$316

$2,346

$413

$1,581

$70

$31,792

5IB School C16-7 U

$18,974

$5,169

$1,430

$158

$2,346

$533

$1,581

$70

$30,262

52B School C14-5 U

$15,812

$3,946

$1,431

$158

$2,346

$533

$1,581

$70

$25,878

53B School C12b-3 U

$15,812

$5,225

$1,431

$158

$2,346

$533

$1,581

$70

$27,156

54B Shuttle C14-5 MP

$15,812

$3,946

$1,431

$158

$2,346

$533

$1,581

$70

$25,878

55B Shuttle C12b-3 MP

$15,812

$5,225

$1,431

$158

$2,346

$533

$1,581

$70

$27,156

56B Shuttle C14-5 U

$15,812

$3,946

$1,431

$158

$2,346

$533

$1,581

$70

$25,878

57B Shuttle C12b-3 U

$15,812

$5,225

$1,431

$158

$2,346

$533

$1,581

$70

$27,156

58B Shuttle C16-7 MP

$18,974

$5,169

$1,430

$158

$2,346

$533

$1,581

$70

$30,262

59B Shuttle C16-7 U

$18,974

$5,169

$1,430

$158

$2,346

$413

$1,581

$70

$30,142

60S Plow C16-7 MP

$18,974

$5,092

$1,430

$158

$2,346

$533

$1,581

$70

$30,185

61S Plow C18 MP

$38,186

$11,097

$2,330

$316

$2,346

$413

$1,581

$70

$56,339

62S Plow C16-7 U

$18,974

$5,092

$1,430

$158

$2,346

$533

$1,581

$70

$30,185

63S Plow C18 U

$30,082

$11,097

$2,330

$158

$2,346

$533

$1,581

$70

$48,197

64V Step C16-7 MP

$18,974

$5,026

$1,430

$158

$2,346

$533

$1,581

$70

$30,119

65V Step C14-5 MP

$15,812

$3,946

$1,431

$158

$2,346

$533

$1,581

$70

$25,878

66V Step C12b-3 MP

$15,812

$4,877

$1,431

$158

$2,346

$533

$1,581

$70

$26,808

67V Step C16-7 U

$18,974

$5,026

$1,430

$158

$2,346

$533

$1,581

$70

$30,119

68V Step C14-5 U

$15,812

$3,946

$1,431

$158

$2,346

$533

$1,581

$70

$25,878

69V Step C12b-3 U

$15,812

$4,877

$1,431

$158

$2,346

$533

$1,581

$70

$26,808

70S Sweep C16-7 U

$18,974

$5,092

$1,430

$158

$2,346

$413

$1,581

$70

$30,064

7IT Tanker C18 R

$38,186

$11,097

$2,330

$316

$2,346

$413

$1,581

$70

$56,339

72T Tanker C18 MP

$30,082

$11,097

$2,330

$316

$2,346

$413

$1,581

$70

$48,235

73T Tanker C18 U

$30,082

$11,097

$2,330

$316

$2,346

$533

$1,581

$70

$48,355

74T Tow C18 R

$38,186

$11,097

$2,330

$316

$2,346

$413

$1,581

$70

$56,339

75T Tow C16-7 R

$18,974

$5,092

$1,430

$158

$2,346

$533

$1,581

$70

$30,185

76T Tow C18 U

$30,082

$11,097

$2,330

$316

$2,346

$533

$1,581

$70

$48,355

77T Tow C16-7 U

$18,974

$5,092

$1,430

$158

$2,346

$413

$1,581

$70

$30,064

78Tractor SC C18 MP

$38,186

$12,908

$1,430

$316

$2,346

$413

$3,162

$174

$58,936

79Tractor SC C18 R

$38,186

$12,908

$2,330

$316

$2,346

$533

$3,162

$174

$59,955

80Tractor DC C18 HH

$40,679

$11,097

$2,330

$316

$2,346

$413

$3,162

$174

$60,518

81 Tractor DC C17 R

$30,082

$7,025

$1,430

$316

$2,346

$533

$3,162

$174

$45,070

82Tractor DC C18 R

$38,186

$12,908

$2,330

$316

$2,346

$413

$3,162

$174

$59,835

83 Tractor DC C17 U

$30,082

$7,025

$1,430

$316

$2,346

$413

$3,162

$174

$44,950

84Tractor DC C18 U

$38,186

$9,213

$2,330

$158

$2,346

$533

$3,162

$174

$56,102

147

-------
Vehicle ID

Engine

Cost
($/unit)

Gearbox
($/unit)

2027
Rule
Cost
($/unit)

Starter

Cost
($/unit)

Mech
Acc.
Cost
($/unit)

Torque
Converter
Clutch
Cost
($/unit)

Final
Drive
Cost
($/unit)

Generator
Cost
($/unit)

ICE
PT
DMC
($/unit)

85B Transit C18 MP

$30,082

$5,762

$2,330

$316

$2,346

$413

$1,581

$70

$42,900

86B Transit C16-7 MP

$18,974

$5,169

$1,430

$158

$2,346

$533

$1,581

$70

$30,262

87B Transit C18 U

$30,082

$5,762

$2,330

$316

$2,346

$413

$1,581

$70

$42,900

88B Transit C16-7 U

$18,974

$5,169

$1,430

$158

$2,346

$413

$1,581

$70

$30,142

89T Utility C18 MP

$38,186

$11,097

$2,330

$158

$2,346

$533

$1,581

$70

$56,301

90T Utility C18 R

$38,186

$11,097

$2,330

$158

$2,346

$533

$1,581

$70

$56,301

91T Utility C16-7 MP

$18,974

$5,092

$1,430

$158

$2,346

$533

$1,581

$70

$30,185

92T Utility C16-7 R

$18,974

$5,092

$1,430

$158

$2,346

$533

$1,581

$70

$30,185

93T Utility C14-5 MP

$15,812

$6,183

$1,431

$158

$2,346

$533

$1,581

$70

$28,115

94T Utility C12b-3 MP

$15,812

$4,877

$1,431

$158

$2,346

$533

$1,581

$70

$26,808

95T Utility C14-5 R

$15,812

$6,183

$1,431

$158

$2,346

$533

$1,581

$70

$28,115

96T Utility C12b-3 R

$15,812

$4,877

$1,431

$158

$2,346

$533

$1,581

$70

$26,808

97T Utility C18 U

$30,082

$11,097

$2,330

$158

$2,346

$533

$1,581

$70

$48,197

98T Utility C16-7 U

$18,974

$5,092

$1,430

$158

$2,346

$533

$1,581

$70

$30,185

99T Utility C14-5 U

$15,812

$6,183

$1,431

$158

$2,346

$533

$1,581

$70

$28,115

100T Utility C12b-3 U

$15,812

$4,877

$1,431

$158

$2,346

$533

$1,581

$70

$26,808

101 Tractor DC C18 U

$38,186

$9,213

$2,330

$316

$2,346

$413

$3,162

$174

$56,140

2.3.3 Diesel Vehicle Fuel Consumption

To estimate fuel consumption for a diesel version of each vehicle type in HD TRUCS, we
assigned the GEM regulatory subcategory ("GEM Duty Cycle") fuel consumption value to the
appropriate vehicle segment in HD TRUCS to get the GEM-weighted fuel consumption by
vehicle type. As previously noted, HVAC is already incorporated into the GEM runs and thus we
did not need to determine HVAC separately for ICE vehicles.

For each regulatory subcategory, grams of C02 emissions from our GEM simulations were
converted to gallons of fuel consumed using a CO2 conversion of 10,180 grams of CO2 per
gallon of diesel.XX1X'42 The gallons of diesel were then divided by the distance of each driving
cycle and weighted appropriately for their respective regulatory subcategories. The results of
these calculations are shown in Table 2-27.

Table 2-27 GEM Fuel Consumption in Miles per Gallon Diesel (MPGD)

GEM Duty Cycle

Fuel Consumption (MPGD)

C8 SC HR

8.5

C8 SC MR

7.8

C8 SC LR

8.5

C8 DC HR

7.5

C8 DC MR

7.2

C8 DC LR

7.8

XXK A value of 10,180 grams of CO2 per gallon of diesel was used as our conversion factor as it was agreed upon as a
common conversion factor between the EPA and Department of Transportation (DOT) in a rulemaking that
established the initial National Program fuel economy standards for model years 2012-2016 (75 FR 25324, May 7,
2010). Available at https://www.epa.gov/energy/greenhouse-gases-equivalencies-calculator-calculations-and-
references

148

-------
GEM Duty Cycle

Fuel Consumption (MPGD)

C7 DC HR

8.6

C7 DC MR

8.2

C7 DC LR

8.9

C8 HH

5.3

HHD R

7.2

HHD M

6.4

HHD U

5.2

MHD R

8.2

MHD M

8.0

MHD U

7.3

LHD R

12.2

LHD M

11.4

LHD U

10.2

8.4

School Bus

7.2

Coach Bus

6.9

Emergency

5.0

Mixer

5.0

Transit Bus

5.2

Refuse Truck

5.0

We then assigned the GEM regulatory subcategory fuel consumption value to the appropriate
vehicle segment in HD TRUCS to get the GEM-weighted fuel consumption by vehicle type. We
also took fuel consumption due to PTO loads into account, as some of the vehicles in HD
TRUCS have auxiliary loads supplied by a PTO. If a vehicle was equipped with a PTO, we
calculated the additional fuel used when operating the PTO. These percent PTO values are a
function of the propulsion ICE values as determined from GEM, where the MPG value for each
Vehicle ID can be found in Table 2-28 (see discussion of PTO loads as a percentage of diesel
fuel consumption in Chapter 2.2.2.1.4). For vehicles without a PTO unit, the percent PTO is
assumed to be zero. The PTO fuel consumption in terms of MPG was then converted into annual
PTO fuel requirement for each vehicle using the annual operational VMT. Table 2-28 shows the
GEM-weighted fuel consumption, gallons of diesel consumed per year by driving, and gallons of
diesel consumed per year by PTO operation.

Table 2-28 Annual Diesel Fuel Consumption from Driving and PTO Use (MY 2027-2032)

GEM Weighted Fuel

Annual Gallons of

Vehicle ID

Consumption

Diesel Consumed -

(MPGD)

Driving

PTO

01V Amb C14-5 MP

11.36

659

02V Amb C12b-3 MP

11.36

960

03V Amb C14-5 U

10.24

843

04V Amb C12b-3 U

10.24

857

05T Box C18 MP

6.39

2,282

06T Box C18 R

7.24

2,013

07T Box C16-7 MP

8.01

1,099

08T Box C16-7 R

8.23

1,069

09T Box C18 U

5.15

2,832

10T Box C16-7 U

7.27

1,181

1 IT Box C12b-3 U

10.24

1,564

149

-------

GEM Weighted Fuel

Annual Gallons of

Vehicle ID

Consumption

Diesel Consumed -

(MPGD)

Driving

PTO

12T Box C12b-3 R

12.15

1,319

13T Box C12b-3 MP

11.36

1,410

14T Box C14-5 U

10.24

1,014

15T Box C14-5 R

12.15

855

16T Box C14-5 MP

11.36

914

17B Coach C18 R

6.92

5,044

18B Coach C18 MP

6.92

5,044

19C Mix C18 MP

5.02

3,934

984

20T Dump C18 U

5.15

1,716

257

21T Dump C18 MP

6.39

1,383

207

22T Dump C16-7 MP

8.01

1,550

232

23 T Dump C18 U

5.15

1,716

257

24T Dump C16-7 U

7.27

1,707

256

25T Fire C18 MP

6.39

1,383

346

26T Fire C18 U

5.15

1,716

429

27T Flat C16-7 MP

8.01

1,099

28T Flat C16-7 R

8.23

1,069

29T Flat C16-7 U

7.27

1,211

30Tractor DC C18 MP

7.77

2,337

31 Tractor DC C16-7 MP

8.92

2,402

32Tractor DC C18 U

7.77

2,337

3 3 Tractor DC C16-7 U

8.92

2,402

34T Ref C18 MP

5.05

2,274

796

35T Ref C16-7 MP

5.05

4,095

1,433

36T Ref C18 U

5.05

2,274

796

37T Ref C16-7 U

5.05

4,095

1,433

38RV C18 R

8.39

282

39RV C16-7 R

8.23

288

40RV C14-5 R

12.15

195

41RV C12b-3 R

12.15

195

42RV C18 MP

8.39

282

43RV C16-7 MP

8.01

296

44RV C14-5 MP

11.36

208

45RV C12b-3 MP

11.36

208

46B School C18 MP

7.19

1,474

47B School C16-7 MP

7.19

1,569

48B School C14-5 MP

11.36

933

49B School C12b-3 MP

11.36

933

5OB School C18 U

7.19

1,474

5 IB School C16-7 U

7.19

1,569

52B School C14-5 U

10.24

1,035

53B School C12b-3 U

10.24

1,035

54B Shuttle C14-5 MP

11.36

2,288

55B Shuttle C12b-3 MP

11.36

2,288

56B Shuttle C14-5 U

10.24

2,538

57B Shuttle C12b-3 U

10.24

2,538

58B Shuttle C16-7 MP

8.01

3,247

59B Shuttle C16-7 U

7.27

3,577

60S Plow C16-7 MP

8.01

1,099

165

61S Plow C18 MP

6.39

1,529

229

62S Plow C16-7 U

7.27

1,211

182

150

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GEM Weighted Fuel

Annual Gallons of

Vehicle ID

Consumption

Diesel Consumed -

(MPGD)

Driving

PTO

63 S Plow C18 U

5.15

1,898

285

64V Step C16-7 MP

8.01

1,680

65V Step C14-5 MP

11.36

741

66V Step C12b-3 MP

11.36

1,154

67V Step C16-7 U

7.27

1,851

68V Step C14-5 U

10.24

822

69V Step C12b-3 U

10.24

1,280

70S Sweep C16-7 U

7.27

1,532

306

71T Tanker C18 R

7.24

1,574

236

72T Tanker C18 MP

6.39

1,784

268

73T Tanker C18 U

5.15

2,214

332

74T Tow C18 R

7.24

1,964

295

75T Tow C16-7 R

8.23

1,505

226

76T Tow C18 U

5.15

2,763

414

77T Tow C16-7 U

7.27

1,704

256

78Tractor SC C18 MP

8.52

5,474

79Tractor SC C18 R

8.52

11,494

80Tractor DC C18 HH

5.34

4,628

81 Tractor DC C17 R

8.92

2,979

82Tractor DC C18 R

7.77

6,133

83Tractor DC C17 U

8.92

2,979

84Tractor DC C18 U

7.77

6,133

85B Transit C18 MP

5.15

5,818

86B Transit C16-7 MP

5.15

3,433

87B Transit C18 U

5.15

5,818

88B Transit C16-7 U

5.15

3,433

89T Utility C18 MP

6.39

923

138

90T Utility C18 R

7.24

814

122

91T Utility C16-7 MP

8.01

1,357

204

92T Utility C16-7 R

8.23

1,320

198

93 T Utility C14-5 MP

11.36

956

143

94T Utility C12b-3 MP

11.36

438

95T Utility C14-5 R

12.15

894

134

96T Utility C12b-3 R

12.15

894

134

97T Utility C18 U

5.15

1,145

172

98T Utility C16-7 U

7.27

1,495

224

99T Utility C14-5 U

10.24

1,061

159

100T Utility C12b-3 U

10.24

486

101 Tractor DC C18 U

7.77

1,813

2.3.4 Diesel Vehicle Operating Costs

Operating costs for HD vehicles encompass a variety of costs, such as labor, insurance,
registration fees, fueling, maintenance and repair (M&R), and other costs. For this analysis, we
are primarily interested in costs that would differ for a comparable diesel-powered ICE vehicle
and a ZEV because these costs will be used to calculate an estimated payback period in HD
TRUCS comparing a ZEV to a similar diesel vehicle (see Chapter 2.7.8 and 2.8.2). For diesels,
we also estimated the cost of the diesel exhaust fluid (DEF) required for the selective catalytic
reduction aftertreatment system. We focus on fueling costs and M&R costs because we expect

151

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these costs to be different for ZEVs than for comparable diesel vehicles, but we do not anticipate
other operating costs, such as labor and insurance, to differ significantly.43 Operating costs were
calculated using the assessment period as described in Chapter 2.2.1.1.3, or the average over a
10-year time period of the annual maintenance and repair (M&R) costs and the annual fuel and
DEF costs.

For each vehicle in HD TRUCS, the 10-year average annual operating costs are as shown in
Table 2-29 and described in the sections below.

Table 2-29 Average Annual M&R and Diesel Fuel Cost for ICE Vehicles for MY 2032 (2021$)

Vehicle ID

Average Annual
VMT (mile)

DEF Cost
($/year)

ICE Vehicle M&R

($/year)

Annual Diesel Cost
($/year)

01V Amb C14-5 MP

7,493

$130

$4,989

$2,165

02V Amb C12b-3 MP

10,914

$189

$7,267

$3,154

03V Amb C14-5 U

8,631

$166

$5,748

$2,767

04V Amb C12b-3 U

8,783

$169

$5,848

$2,816

05T Box C18 MP

14,578

$449

$9,707

$7,493

06T Box C18 R

14,578

$396

$9,707

$6,610

07T Box C16-7 MP

8,800

$216

$5,860

$3,609

08T Box C16-7 R

8,800

$210

$5,860

$3,511

09T Box C18 U

14,578

$557

$9,707

$9,299

10T Box C16-7 U

8,586

$232

$5,717

$3,879

1 IT Box C12b-3 U

16,022

$308

$10,669

$5,136

12T Box C12b-3 R

16,022

$259

$10,669

$4,330

13T Box C12b-3 MP

16,022

$277

$10,669

$4,630

14T Box C14-5 U

10,386

$200

$6,916

$3,330

15T Box C14-5 R

10,386

$168

$6,916

$2,807

16T Box C14-5 MP

10,386

$180

$6,916

$3,002

17B Coach C18 R

34,904

$992

$23,242

$16,563

18B Coach C18 MP

34,904

$992

$23,242

$16,563

19C Mix C18 MP

19,736

$968

$13,142

$16,149

20T Dump C18 U

8,835

$388

$5,883

$6,481

21T Dump C18 MP

8,835

$313

$5,883

$5,222

22T Dump C16-7 MP

12,408

$351

$8,262

$5,852

23 T Dump C18 U

8,835

$388

$5,883

$6,481

24T Dump C16-7 U

12,408

$386

$8,262

$6,447

25T Fire C18 MP

8,835

$340

$5,883

$5,676

26T Fire C18 U

8,835

$422

$5,883

$7,045

27T Flat C16-7 MP

8,800

$216

$5,860

$3,609

28T Flat C16-7 R

8,800

$210

$5,860

$3,511

29T Flat C16-7 U

8,800

$238

$5,860

$3,976

30Tractor DC C18 MP

18,152

$460

$12,087

$7,674

31 Tractor DC C16-7 MP

21,430

$473

$14,270

$7,889

32Tractor DC C18 U

18,152

$460

$12,087

$7,674

3 3 Tractor DC C16-7 U

21,430

$473

$14,270

$7,889

34T Ref C18 MP

11,481

$604

$7,645

$10,082

35T Ref C16-7 MP

20,674

$1,088

$13,767

$18,154

36T Ref C18 U

11,481

$604

$7,645

$10,082

37T Ref C16-7 U

20,674

$1,088

$13,767

$18,154

38RV C18 R

2,368

$56

$1,577

$926

39RV C16-7 R

2,368

$57

$1,577

$945

40RV C14-5 R

2,368

$38

$1,577

$640

152

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Vehicle ID

Average Annual
VMT (mile)

DEF Cost
($/year)

ICE Vehicle M&R

($/year)

Annual Diesel Cost
($/year)

41RV C12b-3 R

2,368

$38

$1,577

$640

42RV C18 MP

2,368

$56

$1,577

$926

43RV C16-7 MP

2,368

$58

$1,577

$971

44RV C14-5 MP

2,368

$41

$1,577

$684

45RV C12b-3 MP

2,368

$41

$1,577

$684

46B School C18 MP

10,602

$290

$7,060

$4,840

47B School C16-7 MP

11,288

$309

$7,517

$5,153

48B School C14-5 MP

10,602

$184

$7,060

$3,064

49B School C12b-3 MP

10,602

$184

$7,060

$3,064

5OB School C18 U

10,602

$290

$7,060

$4,840

5 IB School C16-7 U

11,288

$309

$7,517

$5,153

52B School C14-5 U

10,602

$204

$7,060

$3,399

53B School C12b-3 U

10,602

$204

$7,060

$3,399

54B Shuttle C14-5 MP

26,001

$450

$17,314

$7,514

55B Shuttle C12b-3 MP

26,001

$450

$17,314

$7,514

56B Shuttle C14-5 U

26,001

$499

$17,314

$8,336

57B Shuttle C12b-3 U

26,001

$499

$17,314

$8,336

58B Shuttle C16-7 MP

26,001

$639

$17,314

$10,664

59B Shuttle C16-7 U

26,001

$704

$17,314

$11,747

60S Plow C16-7 MP

8,802

$249

$5,861

$4,152

61S Plow C18 MP

9,772

$346

$6,507

$5,776

62S Plow C16-7 U

8,802

$274

$5,861

$4,573

63 S Plow C18 U

9,772

$430

$6,507

$7,168

64V Step C16-7 MP

13,450

$331

$8,956

$5,516

65V Step C14-5 MP

8,416

$146

$5,604

$2,432

66V Step C12b-3 MP

13,107

$227

$8,728

$3,788

67V Step C16-7 U

13,450

$364

$8,956

$6,077

68V Step C14-5 U

8,416

$162

$5,604

$2,698

69V Step C12b-3 U

13,107

$252

$8,728

$4,202

70S Sweep C16-7 U

11,132

$362

$7,413

$6,035

71T Tanker C18 R

11,397

$356

$7,589

$5,943

72T Tanker C18 MP

11,397

$404

$7,589

$6,737

73T Tanker C18 U

11,397

$501

$7,589

$8,361

74T Tow C18 R

14,225

$444

$9,472

$7,417

75T Tow C16-7 R

12,387

$340

$8,248

$5,682

76T Tow C18 U

14,225

$625

$9,472

$10,435

77T Tow C16-7 U

12,387

$386

$8,248

$6,436

78Tractor SC C18 MP

46,636

$1,077

$11,568

$17,974

79Tractor SC C18 R

97,935

$2,262

$24,293

$37,745

80Tractor DC C18 HH

24,717

$911

$6,131

$15,198

81 Tractor DC C17 R

26,576

$586

$17,697

$9,783

82Tractor DC C18 R

47,634

$1,207

$31,719

$20,138

83Tractor DC C17 U

26,576

$586

$17,697

$9,783

84Tractor DC C18 U

47,634

$1,207

$31,719

$20,138

85B Transit C18 MP

29,976

$1,145

$19,961

$19,105

86B Transit C16-7 MP

17,690

$676

$11,780

$11,275

87B Transit C18 U

29,976

$1,145

$19,961

$19,105

88B Transit C16-7 U

17,690

$676

$11,780

$11,275

89T Utility C18 MP

5,895

$209

$3,926

$3,484

90T Utility C18 R

5,895

$184

$3,926

$3,074

91T Utility C16-7 MP

10,867

$307

$7,236

$5,126

92T Utility C16-7 R

10,867

$299

$7,236

$4,985

153

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Vehicle ID

Average Annual
VMT (mile)

DEF Cost
($/year)

ICE Vehicle M&R

($/year)

Annual Diesel Cost
($/year)

93 T Utility C14-5 MP

10,867

$216

$7,236

$3,612

94T Utility C12b-3 MP

4,973

$99

$3,311

$1,653

95T Utility C14-5 R

10,867

$202

$7,236

$3,378

96T Utility C12b-3 R

10,867

$202

$7,236

$3,378

97T Utility C18 U

5,895

$259

$3,926

$4,325

98T Utility C16-7 U

10,867

$338

$7,236

$5,646

99T Utility C14-5 U

10,867

$240

$7,236

$4,006

100T Utility C12b-3 U

4,973

$110

$3,311

$1,833

101 Tractor DC C18 U

14,080

$357

$3,493

$5,952

2.3.4.1 Diesel Exhaust Fluid Costs

To estimate DEF consumption for a diesel version of each vehicle type in HD TRUCS, we
referenced the work in the final rulemaking, Control of Air Pollution From New Motor Vehicles:
Heavy-Duty Engine and Vehicle Standards xxx (HD 2027 Final Rule). The HD 2027 Final Rule
defined the consumption of DEF as a function of NOx reduction over the Selective Catalyst
Reduction (SCR) system considering Federal Test Procedure (FTP) emissions.™ The engine out
and tailpipe NOx emissions as well as the DEF dosing rate from the HD 2027 Final Rule are
summarized below in Table 2-30.

Table 2-30 DEF Consumption Rates for Diesel Vehicles in HD TRUCS

Value

Engine-out NOx
(FTP g/hp-hr)

4.0

T ailpipe NOx
(FTP g/hp-hr)

0.2

DEF Dose Rate
(% of fuel consumed)

5.18%

The percentage of DEF dosing as a function of diesel fuel consumed was then multiplied by
the sum of Annual Gallons of Diesel Consumed - Driving and Annual Gallons of Diesel
Consumed - PTO (see Table 2-28), and the results are shown in Table 2-31.

Table 2-31 Annual DEF Consumption

Vehicle ID

Annual Gallons of
DEF Consumed

01V Amb C14-5 MP

02V Amb C12b-3 MP

03V Amb C14-5 U

04V Amb C12b-3 U

05T Box C18 MP

118

06T Box C18 R

104

07T Box C16-7 MP

^ 88 FR 4412 (January 24, 2023).

XXX1 The relationship between DEF dose rate and NOx reduction across the SCR catalyst is based on methodology
presented in the Technical Support Document to the 2012 Non-conformance Penalties for On-highway Heavy-duty
Diesel Engines rule (the NCP Technical Support Document, or NCP TSD).

154

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Vehicle ID

Annual Gallons of
DEF Consumed

08T Box C16-7 R

09T Box C18 U

147

10T Box C16-7 U

1 IT Box C12b-3 U

12T Box C12b-3 R

13T Box C12b-3 MP

14T Box C14-5 U

15T Box C14-5 R

16T Box C14-5 MP

17B Coach C18 R

261

18B Coach C18 MP

261

19C Mix C18 MP

255

20T Dump C18 U

102

21T Dump C18 MP

22T Dump C16-7 MP

23 T Dump C18 U

102

24T Dump C16-7 U

102

25T Fire C18 MP

26T Fire C18 U

111

27T Flat C16-7 MP

28T Flat C16-7 R

29T Flat C16-7 U

30Tractor DC C18 MP

121

31 Tractor DC C16-7 MP

124

32Tractor DC C18 U

121

33Tractor DC C16-7 U

124

34T Ref C18 MP

159

35T Ref C16-7 MP

286

36T Ref C18 U

159

37T Ref C16-7 U

286

38RV C18 R

39RV C16-7 R

40RV C14-5 R

41RV C12b-3 R

42RV C18 MP

43RV C16-7 MP

44RV C14-5 MP

45RV C12b-3 MP

46B School C18 MP

47B School C16-7 MP

48B School C14-5 MP

49B School C12b-3 MP

5OB School C18 U

5IB School C16-7 U

52B School C14-5 U

53B School C12b-3 U

54B Shuttle C14-5 MP

119

55B Shuttle C12b-3 MP

119

56B Shuttle C14-5 U

131

57B Shuttle C12b-3 U

131

58B Shuttle C16-7 MP

168

59B Shuttle C16-7 U

185

155

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Vehicle ID

Annual Gallons of
DEF Consumed

60S Plow C16-7 MP

61S Plow C18 MP

62S Plow C16-7 U

63S Plow C18 U

113

64V Step C16-7 MP

65V Step C14-5 MP

66V Step C12b-3 MP

67V Step C16-7 U

68V Step C14-5 U

69V Step C12b-3 U

70S Sweep C16-7 U

7IT Tanker C18 R

72T Tanker C18 MP

106

73T Tanker C18 U

132

74T Tow C18 R

117

75T Tow C16-7 R

76T Tow C18 U

165

77T Tow C16-7 U

102

78Tractor SC C18 MP

284

79Tractor SC C18 R

595

80Tractor DC C18 HH

240

81 Tractor DC C17 R

154

82Tractor DC C18 R

318

83Tractor DC C17 U

154

84Tractor DC C18 U

318

85B Transit C18 MP

301

86B Transit C16-7 MP

178

87B Transit C18 U

301

88B Transit C16-7 U

178

89T Utility C18 MP

90T Utility C18 R

91T Utility C16-7 MP

92T Utility C16-7 R

93T Utility C14-5 MP

94T Utility C12b-3 MP

95T Utility C14-5 R

96T Utility C12b-3 R

97T Utility C18 U

98T Utility C16-7 U

99T Utility C14-5 U

100T Utility C12b-3 U

101 Tractor DC C18 U

2.3.4.2 Maintenance and Repair Cost

Maintenance and repair costs contribute to the overall operating costs for HD vehicles. To
establish a baseline cost for maintenance and repair of diesel-fueled ICE vehicles, we relied on
the research compiled by Burnham et al. in Chapter 3.5.5 of "Comprehensive Total Cost of
Ownership Quantification for Vehicles with Different Size Classes and Powertrains"44 and used
equations found in the BEAN model.45 Burnham et al. used data from Utilimarc and American

156

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Transportation Research Institute (ATRI) to estimate maintenance and repair costs per mile for
multiple heavy-duty vehicle categories over time. We selected the box truck curve to represent
vocational vehicles and short-haul tractorsxxxn, and the semi-tractor curve to represent long-haul
tractors. The increase in M&R is a function of yearly VMT using the rates in Chapter 2.7.2.
M&R cost per mile (2021$/mi) are shown in Figure 2-3. It should be noted that the actual annual
M&R cost follows a non-linear path since yearly VMT increases in the first 4 years and then
decreases after that. Averaging years 0-9 yields about 67 cents per mile for vocational vehicles
and short-haul tractors, and about 25 cents per mile for long-haul tractors, after adjusting to
2021$.

1.2

1.0

0.4

fy*

0.2

0.0

• Vocational & Short Haul

• Lone Haul Tractor

4 6

Year of Ownership

Figure 2-3 M&R Cost Per Mile (2021$/mi)

2.3.4.3 Diesel Fuel Costs

The yearly fuel cost for the HD vehicle is a function of yearly fuel consumption, as described
in Chapter 2.3.3, and the cost of diesel fuel. We used the DOE Energy Information
Administration's (EIA's) Annual Energy Outlook (AEO) 2022 for diesel price. For the
transportation sector, the reference case projection for diesel fuel for on-road use is in Table 2-32
in 2021 dollars.46 This value includes Federal and State taxes but excludes county and local
taxes. The average annual fuel cost is averaged over a 10-year period.

Table 2-32 AEO 2022 Reference Case Diesel Price (2021$)

2027

2028

2029

2030

2031

2032

$/gal

3.15

3.17

3.25

3.27

3.28

2.4 Battery Electric Vehicle Technology

xxxm hgyi tractors and vocational vehicles are represented by the Same M&R equation because they have duty
cycles and annual VMT that are similar.

157

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For the purposes of comparing diesel and BEV technology costs and performance, this section
explains how we define heavy-duty BEVs based on the performance and use criteria in Chapter
2.2. First, we determined BEV battery pack size,xxxm range, and peak motor power requirements
to meet energy and daily operational needs of each vehicle, and we projected energy and fuel use
for each vehicle type (kWh/mi) on an annual basis. Then, we estimated upfront DMC of BEV
components and considered the impacts of the Inflation Reduction Act of 2022 (IRA) tax credits
for heavy-duty electric vehicles. Next, we determined the weight and physical volume of the
battery pack for each of the vehicles to evaluate the impact on payload capability. Finally, we
projected relevant operational costs, averaged over a 10-year period.

2.4.1 BEV Component Sizing

Two of the major components in a BEV are the battery and the motor. The size of these
components is determined by the needs of the specific vehicle. In HD TRUCS, we determined
the battery storage capacity, projected range of the vehicle, and peak motor power requirement
for each of the 101 vehicles represented in HD TRUCS, as described in the following two
subsections. The resulting values are shown in Table 2-33.

Table 2-33 Battery and Motor Sizes (MY 2032)

Vehicle ID

Battery Size (kWh)

Projected Electric Range (mi)

Motor Peak Power (kW)

01V Amb C14-5 MP

257

02V Amb C12b-3 MP

257

03V Amb C14-5 U

257

04V Amb C12b-3 U

257

05T Box C18 MP

295

339

06T Box C18 R

315

339

07T Box C16-7 MP

199

214

08T Box C16-7 R

224

214

09T Box C18 U

273

339

10T Box C16-7 U

205

105

214

1 IT Box C12b-3 U

110

339

12T Box C12b-3 R

139

339

13T Box C12b-3 MP

124

339

14T Box C14-5 U

104

339

15T Box C14-5 R

131

339

16T Box C14-5 MP

117

257

17B Coach C18 R

964

293

339

18B Coach C18 MP

964

293

339

19C Mix C18 MP

367

339

20T Dump C18 U

356

111

339

21T Dump C18 MP

379

111

339

22T Dump C16-7 MP

358

156

214

23 T Dump C18 U

356

111

339

24T Dump C16-7 U

322

156

214

25T Fire C18 MP

390

111

339

26T Fire C18 U

369

111

339

27T Flat C16-7 MP

199

214

28T Flat C16-7 R

224

214

™ Please note that HD TRUCS focuses on the traction battery, which is the rechargeable battery that supplies
power to the electric motor.

158

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Vehicle ID

Battery Size (kWh)

Projected Electric Range (mi)

Motor Peak Power (kW)

29T Flat C16-7 U

178

214

30Tractor DC C18 MP

497

136

554

31 Tractor DC C16-7 MP

440

147

384

32Tractor DC C18 U

497

136

554

3 3 Tractor DC C16-7 U

440

147

384

34T Ref C18 MP

409

118

339

35T Ref C16-7 MP

459

118

214

36T Ref C18 U

409

118

339

37T Ref C16-7 U

459

118

214

38RV C18 R

767

335

339

39RV C16-7 R

815

335

214

40RV C14-5 R

519

335

257

41RV C12b-3 R

519

335

257

42RV C18 MP

767

335

339

43RV C16-7 MP

722

335

214

44RV C14-5 MP

459

335

257

45RV C12b-3 MP

459

335

257

46B School C18 MP

169

339

47B School C16-7 MP

166

214

48B School C14-5 MP

123

257

49B School C12b-3 MP

114

257

5OB School C18 U

160

339

5 IB School C16-7 U

166

214

52B School C14-5 U

111

257

53B School C12b-3 U

102

257

54B Shuttle C14-5 MP

224

150

257

55B Shuttle C12b-3 MP

215

150

257

56B Shuttle C14-5 U

200

150

257

57B Shuttle C12b-3 U

191

150

257

58B Shuttle C16-7 MP

346

150

214

59B Shuttle C16-7 U

309

150

214

60S Plow C16-7 MP

124

214

61S Plow C18 MP

334

339

62S Plow C16-7 U

114

214

63 S Plow C18 U

314

339

64V Step C16-7 MP

222

101

214

65V Step C14-5 MP

257

66V Step C12b-3 MP

117

257

67V Step C16-7 U

198

101

214

68V Step C14-5 U

257

69V Step C12b-3 U

104

257

70S Sweep C16-7 U

208

214

71T Tanker C18 R

353

339

72T Tanker C18 MP

334

339

73T Tanker C18 U

316

339

74T Tow C18 R

567

157

339

75T Tow C16-7 R

403

157

214

76T Tow C18 U

502

157

339

77T Tow C16-7 U

324

157

214

78Tractor SC C18 MP

1468

400

568

79Tractor SC C18 R

2015

550

568

80Tractor DC C18 HH

955

180

1030

159

-------
Vehicle ID

Battery Size (kWh)

Projected Electric Range (mi)

Motor Peak Power (kW)

81 Tractor DC C17 R

637

214

384

82Tractor DC C18 R

1261

349

554

83Tractor DC C17 U

637

214

384

84Tractor DC C18 U

1261

349

554

85B Transit C18 MP

605

203

339

86B Transit C16-7 MP

649

219

214

87B Transit C18 U

605

203

339

88B Transit C16-7 U

649

219

214

89T Utility C18 MP

160

339

90T Utility C18 R

169

339

91T Utility C16-7 MP

214

92T Utility C16-7 R

239

214

93 T Utility C14-5 MP

139

257

94T Utility C12b-3 MP

257

95T Utility C14-5 R

155

257

96T Utility C12b-3 R

155

257

97T Utility C18 U

152

339

98T Utility C16-7 U

194

214

99T Utility C14-5 U

126

257

100T Utility C12b-3 U

257

101 Tractor DC C18 U

465

127

554

2.4.1.1 Battery Pack Energy

In HD TRUCS, we sized the battery based on the expected energy required for the vehicle to
complete operations (i.e., based on the daily sizing VMT). This daily energy consumption is a
function of miles the vehicle is driven and the energy it consumes because of: (1) moving the
vehicle per unit mile, including the impact of regenerative braking, and PTO energy
requirements ("ZEV baseline energy"), (2) battery conditioning and HVAC energy requirements,
and (3) battery efficiency, depth of discharge, and deterioration.

We refer to the energy required to perform required work as "ZEV baseline energy"; this
energy includes energy at the axle used to move the vehicle, regenerative braking energy, and
PTO energy loads, as described in Chapter 2.2.2. The baseline energy loads from Chapter 2.2.2
are reported in terms of kWh/mi, which are converted into kWh/day using the daily sizing VMT.
As previously described in Chapter 2.2.1.2.1, VMT used for sizing the battery pack is higher
than the operational VMT.

The energy required to maintain the battery at a constant temperature (battery conditioning)
and to heat and cool interior cabins (HVAC) are considered separately from the baseline energy,
since these energy loads are not required year-round or in all regions of the country. The HVAC
energy is calculated as a power requirement, which is converted into an energy requirement by
multiplying the HVAC power by the 8-hour operational day. The battery conditioning energy
requirements are determined as a percent of total battery size; a detailed explanation of battery
conditioning may be found in Chapters 2.4.1.1.1 and 2.5.1.2.2

The total daily battery demand is assumed to be the sum of the daily ZEV baseline energy
(including regenerative braking and PTO) as well as battery conditioning and HVAC. The
appropriate losses from the BEV powertrain system (i.e., to account for battery efficiency) are

160

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applied to the battery size. Also, the battery is oversized based on the level of depth of discharge
for an EV battery and to allow for deterioration of the battery over time. A detailed explanation
of the oversizing parameters may be found in Chapter 2.4.1.1.3. The battery pack size for MY
2032 is shown in Table 2-33 for each of the 101 vehicle types.

2.4.1.1.1 HVAC Considerations in a BEV

In this subsection, we describe the HVAC energy requirements, which vary by the cabin size
of the vehicle, and our approach to considering different HVAC requirements across the U.S.

For BEVs, the energy required for cabin thermal management is different than for ICE
vehicles because the vehicle is not able to utilize excess (waste) heat from an engine. BEV could
be equipped with either a positive temperature coefficient (PTC) heater with a traditional A/C, or
a full heat pump system. (See draft RIA Chapter 1 for a description of both). Because heat
pumps are many times more efficient than a PTC heater, a significantly smaller battery is
required for the same duty cycle. This will likely make heat pumps a cost-effective solution in
the heavy-duty sector, considering the avoided upfront costs of a sufficiently larger battery and
reduced electricity costs during operation. Given the success and increasing adoption of heat
pumps in light-duty EVs, we assume the use of heat pumps for heavy-duty vehicles in HD
TRUCS.

To estimate HVAC energy consumption of ZEVs in HD TRUCS, we performed a literature
and market review. Even though there are limited real-world studies, we agreed with the HVAC
modeling approach described in Basma et. al.4' This physics-based cabin thermal model
considers four vehicle characteristics: the cabin interior, walls, and materials, as well as the
number of passengers. The authors modelled a Class 8 electric transit bus with an HVAC system
consisting of two 20 kW-rated reversible heat pumps, an air circulation system, and a battery
thermal management system. The HVAC control strategy is a traditional on-off controller. The
modeled power demand as a function of ambient temperature for the Class 8 transit bus is shown
in Figure 2-4.

Temperature (C)

Figure 2-4 Modeled HVAC Power Demand of a Class 8 Transit Bus as a Function of Ambient Temperature

161

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We recognize that HVAC is not evenly used across the nation. For example, some regions
will be more reliant on heater use while others may depend more on air conditioning. The energy
used for HVAC consumption in HD TRUCS is HVAC energy consumption using Basma for
power demand at a specific temperature and weighted by the percent HD VMT traveled at a
specific temperature range.xxsw To properly account for the temperature variation throughout the
nation and throughout the year, we calculated the percent of HD VMT for several temperature
bins as available from MOVES; this national distribution of VMT as a function of temperature is
shown in Figure 2-5. For example is if power demand from HVAC at 75 °F is 1 kW and the 9.3
percent of FID VMT percent occurs at 75 °F, then the VMT-weighted energy demand is equal to
0.093 kW. Once multiplied, we summed the values that are less than 55 °F and divided by the
percent VMT for temperatures below 55 °F. This method is applied for temperatures between 55
- 80 °F and again for temperatures above 80 °F. This creates three separate bins - one for heating
(<55 °F), one for cooling (>80 °F), and one for a temperature range that requires only ventilation
(55-80 °F). In FID TRUCS, we already accounted for the energy loads due to ventilation in the
axle loads, so no additional energy consumption is applied here for the ventilation-only
operation. We then weighted the power demands by the percent FID VMT traveled at a specific
temperature range. The results of the VMT-weighted HVAC power demand for a Class 8 Transit
Bus are shown in Table 2-34.

<30 30-35 35-40 4045 45-50 50-55 55-60 60-65 65-70 70-75 75-80 80-85 85-90 >90

Temperature (F)

Figure 2-5 MOVES National VMT Distribution as a Function of Temperature for 2b-8 HD Vehicles
Table 2-34 HD TRUCS HVAC Power Consumption of a Class 8 Transit Bus

Temperature (°F) Consumption (kW)

XXHV It should be noted that Basma model has discrete values in Celsius and MOVES data has discrete values in
Fahrenheit. The Basma discrete values in the Basma model is fitted to a parabolic curve and converted into
Fahrenheit to best fit the VMT distribution that is available in MOVES.

162

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Heating

<55

5.06

Ventilation

55-80

0.00

Cooling

>80

3.32

Considering Figure 2-4 and Figure 2-5, VMT-weighted HVAC use is the most significant for
temperatures less than 55 °F and for greater than 80 °F, so we simplified the temperature bins
further in HD TRUCS to only include three bins (<55 °F, 55-80 °F, >80 °F), as shown in Table
2-35.

Table 2-35 Distribution of VMT for HD TRUCS Temperature Bins

Temperature Bins

Heating

<55 °F

55-80 °F

Cooling
>80 °F

% VMT

37%

38%

25%

HVAC load is dependent on cabin size—the larger the size of the cabin, the greater the
HVAC demand. The values for HVAC power demand shown in Table 2-34 represent the power
demand to heat or cool the interior of a Class 8 Transit bus. However, HD vehicles have a range
of cabin sizes; therefore, we developed scaling ratios relative to the cabin size of a Class 8 bus as
shown in Table 2-36. Each vehicle's scaling factor is based on the surface area of the vehicle
compared to the surface area of the Class 8 bus. For example, a Class 4-5 shuttle bus has a cabin
size ratio of 0.6, in this case, the heating demand for the vehicle will be 3.04 kW and the cooling
demand would be 1.99 kW. Cabin sizes for remaining HD vehicles have a similar cabin to a mid-
size light duty vehicle and therefore, a single average scaling factor of 0.2 was applied to all
remaining vehicle types.xxxv

Table 2-36 HD TRUCS Surface Area as a Function of a Class 8 Truck Surface Area

Vehicle ID

Cabin Size ratio

01V Amb C14-5 MP

0.6

02V Amb C12b-3 MP

0.4

03V Amb C14-5 U

0.6

04V Amb C12b-3 U

0.4

17B Coach C18 R

1.0

18B Coach C18 MP

1.0

46B School C18 MP

1.0

47B School C16-7 MP

0.7

48B School C14-5 MP

0.6

49B School C12b-3 MP

0.4

50B School C18 U

0.7

5 IB School C16-7 U

0.7

52B School C14-5 U

0.6

53B School C12b-3 U

0.4

54B Shuttle C14-5 MP

0.6

55B Shuttle C12b-3 MP

0.4

56B Shuttle C14-5 U

0.6

57B Shuttle C12b-3 U

0.4

xxxv The interior cabin where the driver and passengers sit are heated while where the cargo is stored is not heated.

163

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Vehicle ID

Cabin Size ratio

58B Shuttle C16-7 MP

0.7

59B Shuttle C16-7 U

0.7

78Tractor SC C18 MP

0.3

79Tractor SC C18 R

0.3

85B Transit C18 MP

0.7

86B Transit C16-7 MP

0.7

87B Transit C18 U

0.7

88B Transit C16-7 U

0.7

All others

0.2

2.4.1.1.2 Effects of Temperature on the Battery

Battery range and life can be impacted by ambient temperatures, as described in Chapter 1.
Therefore, in general, BEVs have thermal management systems to maintain battery core
temperatures within an optimal range of approximately 68 to 95 degrees Fahrenheit (F) (20 to 35
degrees Celsius).48 Since BEVs may not have an additional energy source beyond what is stored
inside the battery, some stored energy in the battery is used to maintain a constant battery
temperature. The Basma et al. report discusses the battery conditioning power requirements at
various temperatures; Figure 2-6, based on Basma et. al, shows the power demand for battery
conditioning as a function of ambient temperature.49

5
4
3
2

-10 -5 0

25 30 35 40

Figure 2-6 Modeled Power Demand for Battery Conditioning for Class 8 Transit Bus with a 300 kWh Battery

For this we determined the energy consumed to maintain a constant battery temperature for
temperature ranges presented in the Basma et. al paper as well as the VMT distribution by
temperature in MOVES. For each the temperature range modeled are between -10 °C and 40 °C
for Basma et. al paper and 30 °F to 90 °F for MOVES. Similar to the methods used for HVAC in
Chapter 2.4.1.1.1, we simplify the temperature distribution by determining a VMT-weighted
power consumption value for battery conditioning based on the MOVES HD VMT distribution.
This distribution is further simplified by weighing the VMT percentages for temperatures below
55 °F and for temperatures above 80 °F. Then, we determined the energy required for battery

164

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conditioning assuming eight hours of daily operation and expressed it in terms of percent of total
battery size. Table 2-37 shows the energy consumption for battery conditioning for both hot and
cold ambient temperatures, expressed as a percentage of battery capacity.

Table 2-37 VMT Weighted Battery Conditioning Energy Consumption

Ambient Temperature (°F)

Energy Consumption (%)

Battery Heating

<55

1.9%

Battery Cooling

>80

4.2%

2.4.1.1.3 Determining BEVBattery Size

In HD TRUCS, the ZEV baseline energy, HVAC, and battery conditioning demands are
summed for one operational day. The HVAC and battery conditioning demands are added using
a weighted average of these demands by the temperature bins in Table 2-35. These values are
used to determine BEV battery size.

Then, to account for certain losses, we apply efficiency values that take place in the battery,
inverter, and electric motor (e-motor) before the remaining energy arrives at the axle. These
losses are calculated using the efficiency values shown in Table 2-38. The battery efficiency
value is from MOVES.xxxvl The inverter and e-motor efficiency estimates are based on values
used in the "Electric Machine" tab of ANL's 2022 Autonomie for the simulated MYs 2027
through 2032. Limited efficiency data found in Brooker et. al50 and Nair et. al51 looked
comparable. We linearly interpolated an average of the high and low values for 2025, 2030, and
2035. Total System Efficiency (i.e., from the battery to the road) is a product of all three
categories of losses described above.

Table 2-38 BEV Component Efficiencies in MY 2027-2032

Component

2027

2028

2029

2030

2031

2032

Battery

95%

Inverter

97.0%

97.5%

E-Motor

94.5%

95.0%

Total System Efficiency

87%

88%

When sizing the battery, we also accounted for the battery depth of discharge, or the amount
of discharge level during a discharging cycle, and battery deterioration over time. For BEV
battery depth of discharge, we sized the battery by limiting the battery to a maximum depth of
discharge of 80 percent, which is a common allowable depth of discharge for lithium batteries;
therefore, an additional 20 percent increase in battery size is needed to allow a depth of discharge
of 80 percent.52 To account for battery deterioration, the battery is over-sized by 20 percent in
HD TRUCS so that at least 80 percent of original battery capacity is available to account for
potential battery deterioration. These values are multiplied together to determine additional
sizing requirement to account for these parameters.

xxxvl MOVES includes a single battery efficiency value for wall-to-battery of 90 percent efficiency; this would
include battery charging and discharging. Here, we assumed that the efficiency of charging is equal to that of
discharging, therefore 95 percent.

165

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2.4.1.2 E-Motor Sizing Based on Power Needs

The electric motor (e-motor) is part of the electric drive system that converts the electric
power from the battery or fuel cell into mechanical or motive power to move the wheels of the
vehicle. In the case of a BEV, there are losses associated with converting current and voltage
output from the electric motor into mechanical power at any given time. The e-motor is sized to
meet the peak power requirements of each vehicle in HD TRUCS, after accounting for the e-
motor's efficiency used in Table 2-38.

BEVs operate at peak power to accelerate up to a driving speed and to climb steep inclines at
a reasonable pace. Peak power requirements are important to ensure that BEVs can match the
speed-related performance of comparable ICE vehicles. Peak power is the maximum power
required to perform the work of an HD vehicle. To estimate peak power needs to size the e-
motor, we used the maximum power among the peak power requirement generated from the
following performance targets: the peak required during the ARB transient cyclexxxv" and
performance targets included in ANL's Autonomie model53 (see "0-30mph", "0-60mph" in the
Performance Sizing tab) and in Islam et al.54 (for 6 percent Grade Speed), as indicated in Table
2-39. We assigned the target maximum time to accelerate a vehicle from stop to 30 mph and 60
mph based on weight class of each vehicle. We also used the criteria that the vehicle must be
able to maintain a specified cruise speed while traveling up a road with a 6 percent grade, as
shown in Table 2-39. In the case of cruising at 6 percent grade, the road load calculation is set at
a constant speed for each weight class bin on a hill with a 6% percent incline. We determined the
required power rating of the motor as the greatest power required to drive the vehicle over the
ARB transient test cycle, at 55 mph and 65 mph constant cruise speeds, or at constant speed at 6
percent grade, and then applied losses from the e-motor.

Table 2-39 ANL Performance Targets

Vocational

Tractors

Weight Class Bin

2b-3

4-5

6-7

0-30 mph Time (s)

0-60 mph Time (s)

100

Cruise Speed (mph) (2> 6 % grade

2.4.2 Battery Weight and Volume

Performance needs of a BEV can result in a battery that is so large or heavy that it impacts
payload and, thus, potential work accomplished relative to a comparable ICE vehicle. We
determined the battery weight and physical volume for each vehicle application in HD TRUCS
using the specific energy and energy density of the battery for each battery capacity. The
resulting values for 101 HD TRUCS vehicle types are shown in Table 2-40 and the detailed
descriptions for weight and volume determinations, as well as descriptions of specific energy
(Wh/kg) and energy density (Wh/L), are described in Chapters 2.4.2.1 and 2.4.2.2. Here, the

xxxvii epa uses three representative duty cycles for calculating Carbon Dioxide (CO2) emissions in GEM: transient
cycle and two highway cruise cycles. The ARB transient duty cycle was developed by the California Air Resources
Board (CARB) and includes no grade—-just stops and starts. The highway cruise duty cycles represent 55-mph and
65-mph vehicle speeds on a representative highway. They use the same road load profile but at different vehicle
speeds, along with a percent grade ranging from -5 percent to +5 percent.

166

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battery size in kWh is converted into liters (L) and cubic meters (m3) using the energy density of
the battery. To evaluate battery volume, we also estimate the battery's width using the vehicle's
wheelbase and 110 percent of the frame depths described in Table 2-23 and Equation 2-32, with
results shown in Table 2-40.

Table 2-40 Battery Size, Weight, Volume, and Width in MY 2032

Vehicle ID

Battery Size

Battery

Battery Volume

Battery

(kWh)

Weight (kg)

(mA3)

Width (ft)

01V Amb C14-5 MP

399

0.16

0.7

02V Amb C12b-3 MP

444

0.18

0.9

03V Amb C14-5 U

408

0.16

0.7

04V Amb C12b-3 U

337

0.13

0.7

05T Box C18 MP

295

1324

0.53

2.0

06T Box C18 R

315

1413

0.57

2.1

07T Box C16-7 MP

199

893

0.36

1.1

08T Box C16-7 R

224

1005

0.40

1.3

09T Box C18 U

273

1225

0.49

1.8

10T Box C16-7 U

205

920

0.37

1.2

1 IT Box C12b-3 U

110

494

0.20

0.8

12T Box C12b-3 R

139

624

0.25

1.0

13T Box C12b-3 MP

124

556

0.22

0.9

14T Box C14-5 U

104

467

0.19

1.0

15T Box C14-5 R

131

588

0.24

1.2

16T Box C14-5 MP

117

525

0.21

1.1

17B Coach C18 R

964

4325

1.73

2.5

18B Coach C18 MP

964

4325

1.73

2.5

19C Mix C18 MP

367

1647

0.66

2.1

20T Dump C18 U

356

1597

0.64

2.4

21T Dump C18 MP

379

1701

0.68

2.5

22T Dump C16-7 MP

358

1606

0.64

2.0

23 T Dump C18 U

356

1597

0.64

2.4

24T Dump C16-7 U

322

1445

0.58

1.8

25T Fire C18 MP

390

1750

0.70

2.6

26T Fire C18 U

369

1656

0.66

2.4

27T Flat C16-7 MP

199

893

0.36

1.1

28T Flat C16-7 R

224

1005

0.40

1.3

29T Flat C16-7 U

178

799

0.32

1.0

30Tractor DC C18 MP

497

2230

0.89

2.9

31 Tractor DC C16-7 MP

440

1974

0.79

2.6

32Tractor DC C18 U

497

2230

0.89

2.9

3 3 Tractor DC C16-7 U

440

1974

0.79

2.6

34T Ref C18 MP

409

1835

0.73

2.0

35T Ref C16-7 MP

459

2059

0.82

2.6

36T Ref C18 U

409

1835

0.73

2.0

37T Ref C16-7 U

459

2059

0.82

2.6

38RV C18 R

767

3441

1.38

4.3

39RV C16-7 R

815

3657

1.46

4.0

40RV C14-5 R

519

2329

0.93

3.8

41RV C12b-3 R

519

2329

0.93

5.2

42RV C18 MP

767

3441

1.38

4.3

43RV C16-7 MP

722

3239

1.30

3.5

167

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Vehicle ID

Battery Size

Battery

Battery Volume

Battery

(kWh)

Weight (kg)

(mA3)

Width (ft)

44RV C14-5 MP

459

2059

0.82

3.4

45RV C12b-3 MP

459

2059

0.82

4.6

46B School C18 MP

169

758

0.30

1.0

47B School C16-7 MP

166

745

0.30

0.8

48B School C14-5 MP

123

552

0.22

0.9

49B School C12b-3 MP

114

511

0.20

1.1

5OB School C18 U

160

718

0.29

0.9

5 IB School C16-7 U

166

745

0.30

0.8

52B School C14-5 U

111

498

0.20

0.8

53B School C12b-3 U

102

458

0.18

1.0

54B Shuttle C14-5 MP

224

1005

0.40

1.7

55B Shuttle C12b-3 MP

215

965

0.39

2.2

56B Shuttle C14-5 U

200

897

0.36

1.5

57B Shuttle C12b-3 U

191

857

0.34

2.0

58B Shuttle C16-7 MP

346

1552

0.62

1.7

59B Shuttle C16-7 U

309

1386

0.55

1.5

60S Plow C16-7 MP

124

556

0.22

0.7

61S Plow C18 MP

334

1499

0.60

2.2

62S Plow C16-7 U

114

511

0.20

0.6

63 S Plow C18 U

314

1409

0.56

2.1

64V Step C16-7 MP

222

996

0.40

1.2

65V Step C14-5 MP

408

0.16

0.7

66V Step C12b-3 MP

117

525

0.21

1.2

67V Step C16-7 U

198

888

0.36

1.0

68V Step C14-5 U

363

0.15

0.6

69V Step C12b-3 U

104

467

0.19

1.1

70S Sweep C16-7 U

208

933

0.37

1.0

71T Tanker C18 R

353

1584

0.63

2.3

72T Tanker C18 MP

334

1499

0.60

2.2

73T Tanker C18 U

316

1418

0.57

2.1

74T Tow C18 R

567

2544

1.02

3.8

75T Tow C16-7 R

403

1808

0.72

2.3

76T Tow C18 U

502

2252

0.90

3.3

77T Tow C16-7 U

324

1454

0.58

1.8

78Tractor SC C18 MP

1468

6587

2.63

8.5

79Tractor SC C18 R

2015

9041

3.62

11.7

80Tractor DC C18 HH

955

4285

1.71

5.5

81 Tractor DC C17 R

637

2858

1.14

3.7

82Tractor DC C18 R

1261

5658

2.26

7.3

83Tractor DC C17 U

637

2858

1.14

3.7

84Tractor DC C18 U

1261

5658

2.26

7.3

85B Transit C18 MP

605

2715

1.09

2.5

86B Transit C16-7 MP

649

2912

1.16

3.2

87B Transit C18 U

605

2715

1.09

2.5

88B Transit C16-7 U

649

2912

1.16

3.2

89T Utility C18 MP

160

718

0.29

1.1

90T Utility C18 R

169

758

0.30

1.1

91T Utility C16-7 MP

214

960

0.38

1.2

92T Utility C16-7 R

239

1072

0.43

1.4

93 T Utility C14-5 MP

139

624

0.25

1.0

94T Utility C12b-3 MP

345

0.14

0.7

95T Utility C14-5 R

155

695

0.28

1.1

168

-------
Vehicle ID

Battery Size

Battery

Battery Volume

Battery

(kWh)

Weight (kg)

(mA3)

Width (ft)

96T Utility C12b-3 R

155

695

0.28

1.4

97T Utility C18 U

152

682

0.27

1.0

98T Utility C16-7 U

194

870

0.35

1.1

99T Utility C14-5 U

126

565

0.23

0.9

100T Utility C12b-3 U

314

0.13

0.6

101 Tractor DC C18 U

465

2086

0.83

3.3

2.4.2.1 Battery Weight

Battery specific energy (also referred to as gravimetric energy density) is a measure of battery
energy per unit of mass (e.g., watt-hours or Wh per kg). While there have been tremendous
advancements in battery chemistries, materials, and pack design in recent years, current ZEV
batteries add mass to the vehicle. Battery specific energy is expected to continue to improve as
next generation battery technologies are developed.55

To determine the weight impact, we used the specific energy of battery packs with lithium-ion
cell chemistries from medium- and heavy-duty vehicle assumptions in the 2021 version of
Autonomie.56 See "Usable Pack Energy Density" in the Battery tab. HD TRUCS assumptions
represent a mid-range average of ANL's high-tech and low-tech estimates.57 Values for MY
2028 through MY 2032 are linearly interpolated between the 2027, 2030, and 2035 values. The
values used in HD TRUCS are shown in Table 2-41. Battery weight for each vehicle type in each
model year is calculated by dividing the battery size (kWh) by the specific energy (see "Battery
Weight (kg) in Table 2-40.

Table 2-41 Battery Pack-Level Specific Energy in HD TRUCS (Wh/kg)

2027

2028

2029

2030

2031

2032

Specific Energy (Wh/kg)

199

203

208

213

218

223

2.4.2.2 Battery Volume

To evaluate battery volume and determine the packaging space required for each HD vehicle
type, we used battery energy density. We also estimated the battery's width using the wheelbase
and frame depths.

Battery energy density (also referred to as volumetric energy density) is a measure of battery
energy per unit of volume, (e.g., Wh/L). This value was not available as a part of the Autonomie,
nor did we find many projections for battery pack-level specific energy or energy density
specifically for heavy duty vehicles in the literature. For the foreseeable future, battery packs
likely will consist of numerous battery cells where the pack-level energies are lower than that of
the cell-level energies because of added mass or volume from the creation of the module or pack.
Considering the current battery market consists of few battery cell producers, we anticipate that
properties of the heavy-duty vehicle battery cells will follow that of the light-duty battery
market. As energy densities continue to improve over time, more battery pack sizes with more
optimized pack designs are expected in the market. The overall trend of energy density shows a
linear correlation with specific energy. In this analysis, we determined the energy density is 2.5

169

-------
kg/L times that of specific energy, as shown in Table 2-42.XXXV111>58 Battery volume for each
vehicle type in each model year is calculated by dividing the battery size (kWh) by the energy
density, and by considering battery width as shown in Table 2-40.

Table 2-42 Battery Pack Level Energy Density in HD TRUCS (Wh/L)

2027

2028

2029

2030

2031

2032

Energy Density (Wh/L)

496

508

521

533

545

557

2.4.3 BEV Component Costs

A BEV powertrain system has different components than an ICE powertrain system. To
account for differences in powertrain system costs between BEVs and ICEs, we considered the
following HD BEV powertrain systems in HD TRUCS: battery, electric motor, inverter,
converter, onboard charger, power electronics controller, transmission or gearbox, final drive,
and any electrical accessories.

Although there are many components in a BEV, two components play an outsized role in the
cost of the BEV: the battery and the motor. The cost of these components varies depending on
the size of these components which is determined by the requirements of the HD BEV; the sizing
aspect of these components are explained in Chapter 2.4.1. The remaining components, including
the power electronics, gearbox, and final drive impart some cost on the BEV total cost, but to a
much lesser degree.

In HD TRUCS, BEV component DMC are generally estimated from literature values, as
discussed in following sections, for MY 2027 and then extrapolated through MY 2032 using an
EPA learning curve that is described in DRIA Chapter 3.2.1.

As described in Chapter 1.3.2, the IRA provides a tax credit to reduce the cost of producing
qualified batteries (battery tax credit) and to reduce the cost of purchasing qualified ZEVs
(vehicle tax credit).59 The battery tax credit is considered in HD TRUCS before determining the
total incremental cost, as described in Chapter 2.4.3.1. The vehicle tax credit is considered after
determining the total incremental cost (i.e., increase in purchase price) of a BEV relative to a
comparable ICE vehicle, effectively reducing the cost of the BEV for the purchaser. This vehicle
tax credit does not affect the cost of BEVs for the manufacturers, as reflected in our accounting
described in DRIA Chapter 3. Please see Chapter 2.4.3.5 for further discussion of this IRA
vehicle tax credit.

2.4.3.1 EVBattery Cost

The battery is one of the most expensive parts of a BEV powertrain system. Battery costs are
widely discussed in the literature because they are a key driver of the cost of a heavy-duty BEV.
The per unit cost of the battery, in terms of $/kWh, is the most common metric in determining
the cost of the battery as the final size of the battery may vary significantly between different
applications. The total battery pack cost is a function of the per-unit-kWh cost and the size (in
terms of kWh) of the battery pack.

xxxvm Lithium ion batteries have linear dependence between energy density and specific energy. Here, the energy
density to specific energy relationship is determined using data for light-duty vehicles.

170

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The literature reflects numerous disparate projections for battery costs and battery pricing.
Most of the values in the literature were developed prior to enactment of the IRA. Sources do not
always clearly define what is included in their cost or price projections, nor whether projections
reflect DMC incurred by the manufacturer or the prices seen by the end-purchaser. There is
uncertainty in how much production and sales volumes may impact the total pack cost. This
presents a challenge for assessing the cost of the battery pack and the BEV system.

Covid-19 and other global disruptions have placed pressure on battery supply chains that
could affect prices in the short-term. The Federal Consortium for Advanced Batteries published a
National Blueprint for Lithium Batteries in June 2021 to guide investments and developments in
the lithium-battery manufacturing value chain and establish a domestic supply chain that is more
sheltered from global price dynamics.60 BloombergNEF predicted that battery prices could reach
$100/kWh in 2026.61 In December 2022, prices of lithium-ion batteries increased for the first
time in over a decade due to higher raw material and component costs.62

Batteries in the light-duty vehicle market could help accelerate reductions in the cost of
battery pack cells for heavy-duty markets.63 ICCT/Ricardo project that battery pack prices for
commercial vehicles could be as low as $120/kWh by 2030.64 Wang et Al. conducted a literature
review of BEV truck studies and found future year battery cost estimates ranging from $60/kWh
to $158/kWh in 2030.65 Yet one industry report suggests that experience with batteries and
battery sourcing capabilities are widely divergent among commercial EV manufacturers in the
U.S., which may cause stumbling blocks during early market development in the truck sector.66
Increased deployment of battery electric trucks can drive battery price reductions and supply
chain improvements.67 Cost reductions in battery packs for electric trucks are anticipated due to
continued improvement of cell and battery pack performance and advancements in technology
associated with energy density, materials for cells, and battery packaging and integration.68

In 2021, ANL developed heavy-duty vehicle battery pack cost assumptions in their BEAN
model (see "Li-ion High Energy Battery Cost - BEV" in the Vehicle Assumptions tab) that
ranged between the high-tech and low-tech values from $175/kWh to $225/kWh in MY 2027
and dropped to $115/kWh to $150/kWh in MY 2035.69 In a recent update to BEAN, released
after the IRA was passed, their costs ranged from $95/kWh to $128/kWh in MY 2025 to
$70/kWh to $90/kWh in MY 2035.70

In HD TRUCS, the battery DMC for MY 2027 is based on an International Council on Clean
Transportation (ICCT) literature review of costs of zero-emission truck components conducted
by Sharpe and Basma prior to the IRA.71 We considered this source to be a comprehensive
review of the literature at the time of the HD TRUCS analysis for the cost of battery packs in
absence of the IRA, which may mean that it presents higher costs than will be realized with the
incentives in the IRA, even when accounting for the battery tax credit described later in this
section. It reflects an average of estimates for an energy battery pack, which is the type of battery
typically used in a BEV to store enough energy to extend driving range (in comparison to a
power battery, which is mainly used to provide high instantaneous power). In 2025, the average
cost is estimated to be $163.50/kWh (2019$) and, in 2030, the average cost is projected to fall to
$100 (2019$). We assumed a linear interpolation of these values that yields an estimated cost of
$138/kWh (2019$) for MY 2027. MYs 2028-2032 were then calculated using learning rates as
shown in Chapter 3.2.1, and converted to 2021$, resulting in the values shown in Table 2-43.

171

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Per-unit battery cost for each of the 101 vehicles can be seen in Table 2-47 and Table 2-48 for
MYs 2027 and 2032, respectively. Battery costs are projected to drop significantly over time.

Table 2-43 Pack-Level Battery Direct Manufacturing Costs in HD TRUCS (2021$)

$/kWh

MY
2027

MY
2028

MY
2029

MY
2030

MY
2031

MY
2032

Battery Pack Cost

145

134

126

120

115

111

As discussed in Chapter 1.3.2, Section 13502 of the IRA,72 provides tax credits from CY 2023
through CY 2032 for the production and sale of battery cells and modules.

Batteries are the most significant cost component for BEVs and, as discussed in DRIA
Chapter 1.3.2, the IRA section 13502 on "Advanced Manufacturing Production Credit" has the
potential to significantly reduce the cost of BEVs and FCEVs (see Chapter 2.5) whose batteries
are produced in the United States. However, at present, there are few manufacturing plants for
HD vehicle batteries in the United States. As discussed in DRIA Chapter 1.5, we expect that the
industry will respond to this tax credit incentive by building more domestic battery
manufacturing capacity in the coming years. For example, Proterra recently announced its first
heavy-duty battery manufacturing plant in the U.S.,73 Tesla is expanding its facilities in Nevada
to produce its Semi BEV tractor and battery cells,74 and Cummins has entered into an agreement
with Arizona-based Sion Power to design and supply battery cells for commercial electric
vehicle applications.75 In addition, DOE is funding through the BIL battery materials processing
and manufacturing projects to "support new and expanded commercial-scale domestic
facilities to process lithium, graphite and other battery materials, manufacture components, and
demonstrate new approaches, including manufacturing components from recycled materials."76
Thus, we model this tax credit in HD TRUCS such that HD BEV and FCEV manufacturers fully
utilize the module tax credit and gradually increase their utilization of the cell tax credit for MY
2027-2029 until MY 2030 and beyond, when they earn 100 percent of the available cell and
module tax credits. This increase in cell credit utilization, phase-out of the tax credit written into
the statute, and our assumed tax credit values are depicted in Figure 2-7.

172

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100%

CC
>

3 75%

3
o
a

o
a
o

25%

5 0%
o
a,
c

5 50%

2027 2028 2029 2030 2031 2032
Model Year

45
40

-------
per year until fully expiring in 2033."77 In comparison with this ICCT and Energy Innovation
study, our analysis falls between the Low and High scenarios for 2027-2029 and matches the
High scenario for 2030-2032, reflecting our expectation that domestic battery manufacturing
capacity will increase over time to capture this incentive and that competition in the market will
lead manufacturers to reduce prices in accordance with the tax credits earned.

These lower battery prices have the potential to accelerate ZEV technology adoption. For
example, the Rocky Mountain Institute found that because of the IRA, the TCO of electric trucks
will be lower than the TCO of diesel trucks about five years faster than without the law.78

2.4.3.2 E-Drive

The electric drive in a BEV includes the electric motor (e-motor), power electronics and
electrical accessories, and a driveshaft including a transmission system or gearbox. The electric
energy in the form of DC current is provided from the battery; an inverter is used to change the
DC current into AC current for use by the motor. The motorxl then converts the electric power
into mechanical or motive power to move the vehicle. Conversely, the motor also receives AC
current from the regenerative braking, whereby the converter changes it to DC current to be
stored in the battery. Lastly, the transmission or gearbox and final drive reduces the speed of the
motor through a set of gears to an appropriate speed at the axle. Although there is an emerging
trend of replacing the transmission and driveline with an e-axle, which is an electric motor
integrated into the axle, e-axles are not explicitly covered in our cost analysis.xh

Like the battery cost described above, there are disparate electric drive cost projections. One
reason for the differences is what is included in the definition of "electric drive"; some values
include only the electric motor and other values present a more integrated e-
motor/inverter/gearbox (or transmission) combination. For example, Sharpe and Basma et al.
found the average reported e-drive costs—defined as the e-motor, inverter, and transmission
system—to be around $60/kW in 2020, expected to drop to roughly $25/kW by 2030.79 But this
is difficult to compare to values in Nair et. al,80 which include total component costs, where the
motor and inverter costs vary by duty cycle, as shown in Figure 2-8.

xl BEVs and FCEVs with e-motors have high torque, or twisting force, at low motor speeds (i.e., low-end torque),
which can provide benefits for HD ZEVs compared to comparable ICE vehicles, especially for heavy vehicles at
low speed. We did not quantify the potential performance improvements associated with the increase in low-end
torque due to e-motors in the HD TRUCS analysis as we focused on matching ICE vehicle performance rather than
exceeding it.

xh E-axles are an emerging technology that have potential to realize efficiency gains because they have fewer
moving parts. Though we did not quantify their impact explicitly due to a lack of data and information at the time of
our analysis and to remain technology-neutral, the technology can be used to comply with this regulation.

174

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E-Drive Component Costs
(HD Motor Reference & High Case)

SI,800.00
51,600.00
$1.400 00
$1,200.00
51,000.00
5S00.00
5500.00
5400.00
5200.00
50.00

¦ Motor Costs a invmer Costs ¦ Gearbox Costs
Figure 2-8: Electric Drive Component Costs from Nair et. al.81

Both references cite inverter cost rather than power electronics and electronic accessories costs,
which are considered in HD TRUCS. Burke et. al includes electric powertrain costs that
represent the motor, power electronics, and DC-DC converters, but not individual component

costs.82

To remain consistent with other aspects of HD TRUCS and based on the staicture of ANL's
BEAN model in the "Autonomic Out Import" tab, our analysis included cost values of individual
e-drive components per kilowatt (kW): the e-motor, power electronics and electronic accessories,
and gearbox.

2.4.3.2.1 E-Motor

An e-motor—which is another major component of a BEV vehicle83—converts electric
energy from the battery into mechanical energy. We did not find sole $/kW e-motor costs in the
literature. The e-motor costs in HD TRUCS came from ANL's 2022 BEAN model, from
"Integrated Traction Drive Cost" in the Vehicle Assumptions tab.*'" The MY 2027 value is a
linear interpolation of the average of the high- and low-tech scenarios for 2025 and 2030,
adjusted to 2021$. MY 2028-2032 values were then calculated using the learning rates (derived
from a learning curve) in DRIA Chapter 3.2.1. The per-unit cost was calculated from the power
of the motor (Chapter 2.4.1.2) and $/kW of the e-motor (shown in Table 2-45). Per-unit e-motor
cost for each of the 101 vehicles can be seen in Table 2-47 for MY 2027.

Table 2-45 E-Motor Direct Manufacturing Costs in HD TRUCS (2021$)

2027

2028

2029

2030

2031

2032

E-Motor Cost ($/kW)

2.4.3.2.2 Power Electronics and Electric Accessories

Class 3 Class 5 Class 5 Class 7 Class 7 Class S Class 8
Delivery Delivery Shuttle Bus Delivery ScftooJ Bus Refuse Transit Bus
Van Truck Truck Truck

Our assumption is that ANL's integrated cost includes the inverter and the motor.

175

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Power electronics and electric accessories are another electrification component that includes
a DC-DC converter to transition high battery voltage to a common 12V level for auxiliary uses.

One NREL report includes a cost assumption used in FASTSim Powertrain Modeling for
"power electronics with boost and motor" of around $41.70/kW (in 2016 dollars) for medium-
and heavy-duty trucks by 2025.84 EDF/Roush suggest that DC-DC converters, which includes
the cost of the motor, in medium- and heavy-duty vehicles could cost $45.31/kW in 2027.85

The power electronics and electric accessories costs in HD TRUCS came from ANL's BEAN
model. See "Accessories" ($4,500) plus the "DC-DC booster" ($1,500) average costs for BEVs
in the BEAN Results tab. They were learned using the learning rates in DRIA Chapter 3.2.1.

2.4.3.2.3 Gearbox and Final Drive

Gearbox and final drive units are used to reduce the speed of the motor and transmit torque to
the axle of the vehicle. In HD TRUCS, the MY 2027 final drive is set at $l,500/unit, based on
the "Final Drive Costs" column in the "Autonomie Out Import" tab of ANL's BEAN model.86
The learning curve shown in DRIA Chapter 3.2.1 was applied for MY 2028 through MY
2032.xliii

The cost of the gearbox varies depending on the vehicle weight class and duty cycle. In our
assessment, all light heavy-duty BEVs would be direct drive and have no transmission and no
cost, in keeping with ANL's BEAN model. We then mapped BEAN gearbox costs for BEVs
(from the same Autonomie Out Import tab) to the appropriate medium heavy-duty and heavy
heavy-duty vehicles in HD TRUCS.87 Gearbox and final drive costs in HD TRUCS for BEVs are
in Table 2-47.

2.4.3.3 Onboard Chargers

When using a Level 2 charging plug, an onboard charger converts AC power from the grid to
usable DC power via an AC-DC converter for charging the high-voltage battery. When using a
DC fast charger (DCFC), any AC-DC converter is bypassed, and the high-voltage battery is
charged directly.

Nair et al. assumes a value for onboard chargers of $45.31 in 2027, if sized for a four-hour
depot charge.88 The size and cost of an onboard charger can vary based on the battery size and
desired charging time and method, similar to considerations for depot and other offboard
chargers since charge rate is limited by the lower-rated of the two.xllv We did not find additional
estimates for onboard chargers in the literature.

In lieu of more data, for HD TRUCS, we used the onboard charger costs, shown in Table
2-46, from ANL's 2022 BEAN model.89 See "Battery Charger" in the Vehicle Assumptions tab.
The low-tech and high-tech values were averaged for 2025 and 2030, and then MY 2027 was
linearly interpolated and adjusted to 2021$; to calculate MY 2028-2032, the learning curve
shown in DRIA Chapter 3.2.1 was applied.

xlm We chose to apply our learning curve to the BEV Final Drive as we expect the BEV drivetrain to increase in
efficiency and decrease in cost over the time frame of this rule due to experience gained in manufacturing, an
increase in the number of BEVs manufactured, and an industry shift towards e-axles which have fewer components.
xllv Nair et al. note that DCFC chargers bypass the onboard charger and deliver current directly to the battery.

176

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Table 2-46 Onboard Charger Direct Manufacturing Costs in HD TRUCS (2021$)

2027

2028

2029

2030

2031

2032

Onboard Charger Cost ($/unit)

2.4.3.4 Total Upfront BEV Costs

The total upfront BEV DMC is the summation of the per-unit cost of the battery, motor,
power electronics, on-board charger, gearbox, final drive, and accessories. The total technology
DMC for each of the 101 vehicle types can be found in Table 2-47 for MY 2027 and in Table
2-48 for MY 2032.

Table 2-47 Direct Manufacturing BEV Costs Including IRA Tax Credit for MY 2027 (2021$)

Vehicle ID

Battery
Cost with
IRA Tax
Credits
($/unit)

Motor
Cost
($/unit)

Power Elec
($/unit)

Charger
($/unit)

Gearbox
($/unit)

Final
Drive
($/unit)

BEV PT

Cost
($/veh)

01V Amb C14-5 MP

11,904

5,081

6,325

1,581

24,928

02V Amb C12b-3 MP

13,226

5,081

6,325

1,581

26,251

03V Amb C14-5 U

12,168

5,081

6,325

1,581

25,193

04V Amb C12b-3 U

9,920

5,081

6,325

1,581

22,944

05T Box C18 MP

39,414

6,685

6,325

4,407

1,581

58,449

06T Box C18 R

42,192

6,685

6,325

4,407

1,581

61,227

07T Box C16-7 MP

26,585

4,225

6,325

2,439

1,581

41,193

08T Box C16-7 R

30,024

4,225

6,325

2,439

1,581

44,632

09T Box C18 U

36,504

6,685

6,325

4,407

1,581

55,539

10T Box C16-7 U

27,511

4,225

6,325

2,439

1,581

42,119

1 IT Box C12b-3 U

14,681

6,685

6,325

1,581

29,309

12T Box C12b-3 R

18,649

6,685

6,325

1,581

33,277

13T Box C12b-3 MP

16,533

6,685

6,325

1,581

31,161

14T Box C14-5 U

13,888

6,685

6,325

1,581

28,516

15T Box C14-5 R

17,591

6,685

6,325

1,581

32,219

16T Box C14-5 MP

15,607

5,081

6,325

1,581

28,631

17B Coach C18 R

128,824

6,685

6,325

2,514

1,581

145,966

18B Coach C18 MP

128,824

6,685

6,325

2,514

1,581

145,966

19C Mix C18 MP

49,069

6,685

6,325

4,407

1,581

68,104

20T Dump C18 U

47,615

6,685

6,325

4,407

1,581

66,649

21T Dump C18 MP

50,657

6,685

6,325

4,407

1,581

69,692

22T Dump C16-7 MP

47,879

4,225

6,325

2,347

1,581

62,395

23 T Dump C18 U

47,615

6,685

6,325

4,407

1,581

66,649

24T Dump C16-7 U

43,118

4,225

6,325

2,347

1,581

57,634

25T Fire C18 MP

52,111

6,685

6,325

4,407

1,581

71,146

26T Fire C18 U

49,334

6,685

6,325

4,407

1,581

68,369

27T Flat C16-7 MP

26,585

4,225

6,325

2,347

1,581

41,101

28T Flat C16-7 R

30,024

4,225

6,325

2,347

1,581

44,540

29T Flat C16-7 U

23,675

4,225

6,325

2,347

1,581

38,191

30Tractor DC C18 MP

66,396

10,924

6,325

4,266

3,162

91,111

31 Tractor DC C16-7 MP

58,857

7,576

6,325

2,318

3,162

78,276

32Tractor DC C18 U

66,396

10,924

6,325

3,637

3,162

90,482

3 3 Tractor DC C16-7 U

58,857

7,576

6,325

2,318

3,162

78,276

34T Ref C18 MP

54,624

6,685

6,325

3,418

1,581

72,671

177

-------
Vehicle ID

Battery
Cost with
IRA Tax
Credits
($/unit)

Motor
Cost
($/unit)

Power Elec
($/unit)

Charger
($/unit)

Gearbox
($/unit)

Final
Drive
($/unit)

BEVPT

Cost
($/veh)

35T Ref C16-7 MP

61,370

4,225

6,325

2,347

1,581

75,886

36T Ref C18 U

54,624

6,685

6,325

3,418

1,581

72,671

37T Ref C16-7 U

61,370

4,225

6,325

2,347

1,581

75,886

38RV C18 R

102,504

6,685

6,325

2,514

1,581

119,646

39RV C16-7 R

108,984

4,225

6,325

2,287

1,581

123,441

40RV C14-5 R

69,306

5,081

6,325

1,581

82,330

41RV C12b-3 R

69,306

5,081

6,325

1,581

82,330

42RV C18 MP

102,504

6,685

6,325

2,514

1,581

119,646

43RV C16-7 MP

96,552

4,225

6,325

2,287

1,581

111,008

44RV C14-5 MP

61,370

5,081

6,325

1,581

74,394

45RV C12b-3 MP

61,370

5,081

6,325

1,581

74,394

46B School C18 MP

22,617

6,685

6,325

2,514

1,581

39,759

47B School C16-7 MP

22,220

4,225

6,325

2,287

1,581

36,677

48B School C14-5 MP

16,401

5,081

6,325

1,581

29,425

49B School C12b-3 MP

15,210

5,081

6,325

1,581

28,235

5OB School C18 U

21,427

6,685

6,325

2,514

1,581

38,568

5 IB School C16-7 U

22,220

4,225

6,325

2,287

1,581

36,677

52B School C14-5 U

14,813

5,081

6,325

1,581

27,838

53B School C12b-3 U

13,623

5,081

6,325

1,581

26,647

54B Shuttle C14-5 MP

29,891

5,081

6,325

1,581

42,916

55B Shuttle C12b-3 MP

28,701

5,081

6,325

1,581

41,725

56B Shuttle C14-5 U

26,717

5,081

6,325

1,581

39,741

57B Shuttle C12b-3 U

25,527

5,081

6,325

1,581

38,551

58B Shuttle C16-7 MP

46,160

4,225

6,325

2,287

1,581

60,616

59B Shuttle C16-7 U

41,398

4,225

6,325

2,287

1,581

55,855

60S Plow C16-7 MP

16,533

4,225

6,325

2,347

1,581

31,049

61S Plow C18 MP

44,573

6,685

6,325

4,407

1,581

63,607

62S Plow C16-7 U

15,210

4,225

6,325

2,347

1,581

29,726

63 S Plow C18 U

41,927

6,685

6,325

4,407

1,581

60,962

64V Step C16-7 MP

29,759

4,225

6,325

2,283

1,581

44,211

65V Step C14-5 MP

12,168

5,081

6,325

1,581

25,193

66V Step C12b-3 MP

15,607

5,081

6,325

1,581

28,631

67V Step C16-7 U

26,453

4,225

6,325

2,283

1,581

40,904

68V Step C14-5 U

10,846

5,081

6,325

1,581

23,870

69V Step C12b-3 U

13,888

5,081

6,325

1,581

26,912

70S Sweep C16-7 U

27,775

4,225

6,325

2,347

1,581

42,291

71T Tanker C18 R

47,218

6,685

6,325

4,407

1,581

66,253

72T Tanker C18 MP

44,705

6,685

6,325

4,407

1,581

63,740

73T Tanker C18 U

42,192

6,685

6,325

4,407

1,581

61,227

74T Tow C18 R

75,787

6,685

6,325

4,407

1,581

94,821

75T Tow C16-7 R

53,831

4,225

6,325

2,347

1,581

68,347

76T Tow C18 U

67,057

6,685

6,325

4,407

1,581

86,092

77T Tow C16-7 U

43,250

4,225

6,325

2,347

1,581

57,766

78Tractor SC C18 MP

196,278

11,214

6,325

5,138

3,162

222,155

79Tractor SC C18 R

269,287

11,214

6,325

5,138

3,162

295,164

80Tractor DC C18 HH

127,633

20,331

6,325

4,407

3,162

161,896

81 Tractor DC C17 R

85,177

7,576

6,325

2,318

3,162

104,596

82Tractor DC C18 R

168,635

10,924

6,325

5,147

3,162

194,230

83Tractor DC C17 U

85,177

7,576

6,325

2,318

3,162

104,596

178

-------
Vehicle ID

Battery
Cost with
IRA Tax
Credits
($/unit)

Motor
Cost
($/unit)

Power Elec
($/unit)

Charger
($/unit)

Gearbox
($/unit)

Final
Drive
($/unit)

BEV PT

Cost
($/veh)

84Tractor DC C18 U

168,635

10,924

6,325

3,637

3,162

192,721

85B Transit C18 MP

80,812

6,685

6,325

2,514

1,581

97,954

86B Transit C16-7 MP

86,764

4,225

6,325

2,287

1,581

101,221

87B Transit C18 U

80,812

6,685

6,325

2,514

1,581

97,954

88B Transit C16-7 U

86,764

4,225

6,325

2,287

1,581

101,221

89T Utility C18 MP

21,427

6,685

6,325

4,407

1,581

40,461

90T Utility C18 R

22,617

6,685

6,325

4,407

1,581

41,652

91T Utility C16-7 MP

28,701

4,225

6,325

2,347

1,581

43,217

92T Utility C16-7 R

31,875

4,225

6,325

2,347

1,581

46,391

93 T Utility C14-5 MP

18,649

5,081

6,325

1,581

31,673

94T Utility C12b-3 MP

10,316

5,081

6,325

1,581

23,341

95T Utility C14-5 R

20,633

5,081

6,325

1,581

33,657

96T Utility C12b-3 R

20,633

5,081

6,325

1,581

33,657

97T Utility C18 U

20,368

6,685

6,325

4,407

1,581

39,403

98T Utility C16-7 U

25,923

4,225

6,325

2,347

1,581

40,439

99T Utility C14-5 U

16,930

5,081

6,325

1,581

29,954

100T Utility C12b-3 U

9,391

5,081

6,325

1,581

22,415

101 Tractor DC C18 U

62,163

10,924

6,325

3,637

3,162

86,249

Table 2-48 Direct Manufacturing BEV Costs and IRA Tax Credit for MY 2032 (2021$)

Vehicle ID

Battery Cost
With IRA
Tax Credits
($/unit)

Motor
Cost
($/unit)

Power
Elec
($/unit)

Charger
($/unit)

Gearbox
($/unit)

Final
Drive
($/unit)

BEV PT
Cost ($/veh)

01V Amb C14-5 MP

9,186

3,861

4,252

1,208

18,536

02V Amb C12b-3 MP

10,218

3,861

4,252

1,208

19,568

03V Amb C14-5 U

9,392

3,861

4,252

1,208

18,743

04V Amb C12b-3 U

7,741

3,861

4,252

1,208

17,091

05T Box C18 MP

30,448

5,080

4,252

3,367

1,208

44,384

06T Box C18 R

32,512

5,080

4,252

3,367

1,208

46,448

07T Box C16-7 MP

20,540

3,211

4,252

1,864

1,208

31,103

08T Box C16-7 R

23,120

3,211

4,252

1,864

1,208

33,684

09T Box C18 U

28,177

5,080

4,252

3,367

1,208

42,113

10T Box C16-7 U

21,159

3,211

4,252

1,864

1,208

31,723

1 IT Box C12b-3 U

11,354

5,080

4,252

1,208

21,923

12T Box C12b-3 R

14,347

5,080

4,252

1,208

24,916

13T Box C12b-3 MP

12,799

5,080

4,252

1,208

23,368

14T Box C14-5 U

10,734

5,080

4,252

1,208

21,303

15T Box C14-5 R

13,521

5,080

4,252

1,208

24,090

16T Box C14-5 MP

12,076

3,861

4,252

1,208

21,426

17B Coach C18 R

99,498

5,080

4,252

1,920

1,208

111,988

18B Coach C18 MP

99,498

5,080

4,252

1,920

1,208

111,988

19C Mix C18 MP

37,880

5,080

4,252

3,367

1,208

51,815

20T Dump C18 U

36,744

5,080

4,252

3,367

1,208

50,680

21T Dump C18 MP

39,118

5,080

4,252

3,367

1,208

53,054

22T Dump C16-7 MP

36,951

3,211

4,252

1,793

1,208

47,444

23T Dump C18 U

36,744

5,080

4,252

3,367

1,208

50,680

179

-------
Vehicle ID

Battery Cost
With IRA
Tax Credits
($/unit)

Motor
Cost
($/unit)

Power
Elec
($/unit)

Charger
($/unit)

Gearbox
($/unit)

Final
Drive
($/unit)

BEV PT
Cost ($/veh)

24T Dump C16-7 U

33,235

3,211

4,252

1,793

1,208

43,728

25T Fire C18 MP

40,254

5,080

4,252

3,367

1,208

54,189

26T Fire C18 U

38,086

5,080

4,252

3,367

1,208

52,022

27T Flat C16-7 MP

20,540

3,211

4,252

1,793

1,208

31,033

28T Flat C16-7 R

23,120

3,211

4,252

1,793

1,208

33,613

29T Flat C16-7 U

18,372

3,211

4,252

1,793

1,208

28,865

30Tractor DC C18 MP

51,297

8,302

4,252

3,259

2,416

69,556

31 Tractor DC C16-7 MP

45,414

5,758

4,252

1,771

2,416

59,640

32Tractor DC C18 U

51,297

8,302

4,252

2,779

2,416

69,075

33Tractor DC C16-7 U

45,414

5,758

4,252

1,771

2,416

59,640

34T Ref C18 MP

42,215

5,080

4,252

2,611

1,208

55,395

35T Ref C16-7 MP

47,375

3,211

4,252

1,793

1,208

57,868

36T Ref C18 U

42,215

5,080

4,252

2,611

1,208

55,395

37T Ref C16-7 U

47,375

3,211

4,252

1,793

1,208

57,868

38RV C18 R

79,165

5,080

4,252

1,920

1,208

91,655

39RV C16-7 R

84,120

3,211

4,252

1,748

1,208

94,567

40RV C14-5 R

53,568

3,861

4,252

1,208

62,918

41RV C12b-3 R

53,568

3,861

4,252

1,208

62,918

42RV C18 MP

79,165

5,080

4,252

1,920

1,208

91,655

43RV C16-7 MP

74,521

3,211

4,252

1,748

1,208

84,968

44RV C14-5 MP

47,375

3,861

4,252

1,208

56,725

45RV C12b-3 MP

47,375

3,861

4,252

1,208

56,725

46B School C18 MP

17,443

5,080

4,252

1,920

1,208

29,933

47B School C16-7 MP

17,134

3,211

4,252

1,748

1,208

27,581

48B School C14-5 MP

12,695

3,861

4,252

1,208

22,046

49B School C12b-3 MP

11,766

3,861

4,252

1,208

21,117

5OB School C18 U

16,514

5,080

4,252

1,920

1,208

29,004

5IB School C16-7 U

17,134

3,211

4,252

1,748

1,208

27,581

52B School C14-5 U

11,457

3,861

4,252

1,208

20,807

53B School C12b-3 U

10,528

3,861

4,252

1,208

19,878

54B Shuttle C14-5 MP

23,120

3,861

4,252

1,208

32,470

55B Shuttle C12b-3 MP

22,191

3,861

4,252

1,208

31,541

56B Shuttle C14-5 U

20,643

3,861

4,252

1,208

29,993

57B Shuttle C12b-3 U

19,714

3,861

4,252

1,208

29,064

58B Shuttle C16-7 MP

35,712

3,211

4,252

1,748

1,208

46,160

59B Shuttle C16-7 U

31,893

3,211

4,252

1,748

1,208

42,341

60S Plow C16-7 MP

12,799

3,211

4,252

1,793

1,208

23,292

61S Plow C18 MP

34,474

5,080

4,252

3,367

1,208

48,409

62S Plow C16-7 U

11,766

3,211

4,252

1,793

1,208

22,260

63S Plow C18 U

32,409

5,080

4,252

3,367

1,208

46,345

64V Step C16-7 MP

22,914

3,211

4,252

1,744

1,208

33,358

65V Step C14-5 MP

9,392

3,861

4,252

1,208

18,743

66V Step C12b-3 MP

12,076

3,861

4,252

1,208

21,426

67V Step C16-7 U

20,436

3,211

4,252

1,744

1,208

30,881

68V Step C14-5 U

8,360

3,861

4,252

1,208

17,711

69V Step C12b-3 U

10,734

3,861

4,252

1,208

20,084

70S Sweep C16-7 U

21,469

3,211

4,252

1,793

1,208

31,962

7IT Tanker C18 R

36,435

5,080

4,252

3,367

1,208

50,370

72T Tanker C18 U

34,474

5,080

4,252

3,367

1,208

48,409

73T Tanker C18 U

32,616

5,080

4,252

3,367

1,208

46,551

180

-------
Vehicle ID

Battery Cost
With IRA
Tax Credits
($/unit)

Motor
Cost
($/unit)

Power
Elec
($/unit)

Charger
($/unit)

Gearbox
($/unit)

Final
Drive
($/unit)

BEV PT
Cost ($/veh)

74T Tow C18 R

58,522

5,080

4,252

3,367

1,208

72,458

75T Tow C16-7 R

41,595

3,211

4,252

1,793

1,208

52,088

76T Tow C18 U

51,814

5,080

4,252

3,367

1,208

65,749

77T Tow C16-7 U

33,441

3,211

4,252

1,793

1,208

43,935

78Tractor SC C17 R

151,518

8,523

4,252

3,925

2,416

170,663

79Tractor SC C18 R

207,977

8,523

4,252

3,925

2,416

227,121

80Tractor DC C18 HH

98,570

15,451

4,252

3,367

2,416

124,084

81 Tractor DC C17 R

65,747

5,758

4,252

1,771

2,416

79,973

82Tractor DC C18 R

130,153

8,302

4,252

3,932

2,416

149,084

83 Tractor DC C17 U

65,747

5,758

4,252

1,771

2,416

79,973

84Tractor DC C18 U

130,153

8,302

4,252

2,779

2,416

147,931

85B Transit C18 MP

62,445

5,080

4,252

1,920

1,208

74,934

86B Transit C16-7 MP

66,986

3,211

4,252

1,748

1,208

77,434

87B Transit C18 U

62,445

5,080

4,252

1,920

1,208

74,934

88B Transit C16-7 U

66,986

3,211

4,252

1,748

1,208

77,434

89T Utility C18 MP

16,514

5,080

4,252

3,367

1,208

30,450

90T Utility C18 R

17,443

5,080

4,252

3,367

1,208

31,379

91T Utility C16-7 MP

22,088

3,211

4,252

1,793

1,208

32,581

92T Utility C16-7 R

24,668

3,211

4,252

1,793

1,208

35,161

93T Utility C14-5 MP

14,347

3,861

4,252

1,208

23,697

94T Utility C12b-3 MP

7,947

3,861

4,252

1,208

17,298

95T Utility C14-5 R

15,998

3,861

4,252

1,208

25,348

96T Utility C12b-3 R

15,998

3,861

4,252

1,208

25,348

97T Utility C18 U

15,689

5,080

4,252

3,367

1,208

29,624

98T Utility C16-7 U

20,024

3,211

4,252

1,793

1,208

30,517

99T Utility C14-5 U

13,005

3,861

4,252

1,208

22,355

100T Utility C12b-3 U

7,225

3,861

4,252

1,208

16,575

101 Tractor DC C18 U

47,995

8,302

4,252

2,779

2,416

65,772

2.4.3.5 Qualified Commercial Clean Vehicle Tax Credits

IRA section 13403, "Qualified Commercial Clean Vehicles," creates a tax credit for the
purchase or lease of a qualified commercial clean vehicle.90 To develop the technology package
that demonstrates the feasibility of the proposed standards, we limited our quantitative analysis
of the IRA to the battery tax credit described in Chapter 2.4.3.1 and this vehicle tax credit. As
described in Section I and Section II of the preamble, and Chapter 1, Chapter 2.4.3.1, and
Chapter 2.6.5.2 of the DRIA, there are several other provisions in the IRA that we expect will
support electrification of the HD vehicle fleet.

Specifically, IRA section 13403 creates a tax credit applicable to each purchase of a qualified
commercial clean vehicle. These vehicles must be on-road vehicles (or mobile machinery) that
are propelled to a significant extent by a battery-powered electric motor. The battery must have a
capacity of at least 15 kWh (or 7 kWh if it is Class 3 or below) and must be rechargeable from an
external source of electricity. This limits the qualified vehicles to BEVs, plug-in hybrid electric
vehicles (PHEVs)xlv, and FCEVs (see Chapter 2.5.2.3).

xlv We did not analyze PHEVs because they were not part of our technology package in this proposal.

181

-------
The credit is available from CY 2023 through 2032, which overlaps with the model years for
which we are proposing standards (MYs 2027-2032), so we included the tax credit in our
calculations for each of those years in HD TRUCS. For BEVs, the tax credit is equal to the lesser
of: (A) 30 percent of the BEV cost, or (B) the incremental cost of a BEV when compared to a
comparable ICE vehicle. The limit of this tax credit is $40,000 for Class 4-8 commercial
vehicles and $7,500 for commercial vehicles Class 3 and below. For example, if a BEV costs
$350,000 and a comparable ICE vehicle costs $150,00091 the tax credit would be the lesser of:

(A) 30 percent x $350,000 = $105,000 or (B) $350,000 - $150,000 = $200,000. (A) is less than

(B), but (A) exceeds the limit of $40,000, so the tax credit would be $40,000.

In order to estimate the impact of this tax credit in our feasibility analysis for BEVs, we first
applied a retail price equivalent to our direct manufacturing costs for BEVs, FCEVs, and ICE
vehicles. Note that the direct manufacturing costs of BEVs were reduced by the amount of the
battery tax credit in IRA section 13502, as described previously and in Chapter 2.4.3.1. We
calculated the purchaser's incremental cost of BEVs compared to ICE vehicles and not the full
cost of vehicles in our analysis. We based our calculation of the tax credit on this incremental
cost. When the incremental cost exceeded the tax credit limitation (determined by gross vehicle
weight rating as described in the previous paragraph), we decreased the incremental cost by the
tax credit limitation. When the incremental cost was between $0 and the tax credit limitation, we
reduced the incremental cost to $0 (i.e., the tax credit received by the purchaser was equal to the
incremental cost). When the incremental cost was negative (i.e., the BEV was cheaper to
purchase than the ICE vehicle), no tax credit was given. In order for this calculation to be
appropriate, we determined that all Class 4-8 BEVs must cost more than $133,333 such that 30
percent of the cost is at least $40,000 (or $25,000 and $7,500, respectively, for BEVs Class 3 and
below), and determined that this assumption is reasonable based on our review of the literature
on the costs of BEVs.92

2.4.4 BEV Operating Costs

Operating costs for HD vehicles encompass a variety of costs, such as labor, insurance,
registration fees, fueling and charging, maintenance and repair (M&R), and other costs. For this
analysis, we are primarily interested in costs that would differ for a comparable diesel-powered
ICE vehicle and a ZEV. These operational cost differences are used to calculate an estimated
payback period in HD TRUCS. We expect fueling and charging costs and M&R costs to be
different for ZEVs than for comparable diesel-fueled ICE vehicles, but we do not anticipate other
operating costs, such as labor and insurance, to differ significantly, so the following subsections
focus on M&R and fueling or charging costs.

In HD TRUCS, costs to operate a BEV include 10-year average annual electricity costs and
10-year average annual maintenance and repair costs, as described in the following sections and
shown in Table 2-49.

Table 2-49 BEV Operating Costs for a MY 2032 Vehicle (2021$)

Vehicle ID

Annual BEV M&R

($/year)

Annual Electricity
Cost ($/year)

01V Amb C14-5 MP

$3,542

$1,062

02V Amb C12b-3 MP

$5,160

$1,352

03V Amb C14-5 U

$4,081

$1,075

182

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Vehicle ID

Annual BEV M&R

($/year)

Annual Electricity
Cost ($/year)

04V Amb C12b-3 U

$4,152

$1,011

05T Box C18 MP

$6,892

$3,823

06T Box C18 R

$6,892

$4,084

07T Box C16-7 MP

$4,161

$1,558

08T Box C16-7 R

$4,161

$1,754

09T Box C18 U

$6,892

$3,535

10T Box C16-7 U

$4,059

$1,346

1 IT Box C12b-3 U

$7,575

$1,634

12T Box C12b-3 R

$7,575

$2,064

13T Box C12b-3 MP

$7,575

$1,837

14T Box C14-5 U

$4,910

$1,064

15T Box C14-5 R

$4,910

$1,343

16T Box C14-5 MP

$4,910

$1,196

17B Coach C18 R

$16,502

$9,177

18B Coach C18 MP

$16,502

$9,177

19C Mix C18 MP

$9,331

$5,924

20T Dump C18 U

$4,177

$2,259

21T Dump C18 MP

$4,177

$2,409

22T Dump C16-7 MP

$5,866

$2,277

23T Dump C18 U

$4,177

$2,259

24T Dump C16-7 U

$5,866

$2,049

25T Fire C18 MP

$4,177

$2,478

26T Fire C18 U

$4,177

$2,344

27T Flat C16-7 MP

$4,161

$1,558

28T Flat C16-7 R

$4,161

$1,754

29T Flat C16-7 U

$4,161

$1,388

30Tractor DC C18 MP

$8,582

$5,284

31 Tractor DC C16-7 MP

$10,132

$5,115

32Tractor DC C18 U

$8,582

$5,284

33Tractor DC C16-7 U

$10,132

$5,115

34T Ref C18 MP

$5,428

$3,170

35T Ref C16-7 MP

$9,774

$6,406

36T Ref C18 U

$5,428

$3,170

37T Ref C16-7 U

$9,774

$6,406

38RV C18 R

$1,119

$433

39RV C16-7 R

$1,119

$460

40RV C14-5 R

$1,119

$293

41RV C12b-3 R

$1,119

$293

42RV C18 MP

$1,119

$433

43RV C16-7 MP

$1,119

$407

44RV C14-5 MP

$1,119

$259

45RV C12b-3 MP

$1,119

$259

46B School C18 MP

$5,012

$1,911

47B School C16-7 MP

$5,337

$1,885

48B School C14-5 MP

$5,012

$1,384

49B School C12b-3 MP

$5,012

$1,288

5OB School C18 U

$5,012

$1,806

5IB School C16-7 U

$5,337

$1,885

52B School C14-5 U

$5,012

$1,250

53B School C12b-3 U

$5,012

$1,154

54B Shuttle C14-5 MP

$12,293

$3,096

55B Shuttle C12b-3 MP

$12,293

$2,979

183

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Vehicle ID

Annual BEV M&R

($/year)

Annual Electricity
Cost ($/year)

56B Shuttle C14-5 U

$12,293

$2,767

57B Shuttle C12b-3 U

$12,293

$2,650

58B Shuttle C16-7 MP

$12,293

$4,784

59B Shuttle C16-7 U

$12,293

$4,281

60S Plow C16-7 MP

$4,162

$1,797

61S Plow C18 MP

$4,620

$2,704

62S Plow C16-7 U

$4,162

$1,645

63S Plow C18 U

$4,620

$2,546

64V Step C16-7 MP

$6,359

$2,372

65V Step C14-5 MP

$3,979

$989

66V Step C12b-3 MP

$6,197

$1,509

67V Step C16-7 U

$6,359

$2,111

68V Step C14-5 U

$3,979

$882

69V Step C12b-3 U

$6,197

$1,343

70S Sweep C16-7 U

$5,263

$1,982

7IT Tanker C18 R

$5,388

$3,365

72T Tanker C18 MP

$5,388

$3,184

73T Tanker C18 U

$5,388

$3,007

74T Tow C18 R

$6,725

$4,111

75T Tow C16-7 R

$5,856

$2,545

76T Tow C18 U

$6,725

$3,644

77T Tow C16-7 U

$5,856

$2,044

78Tractor SC C18 MP

$8,213

$13,668

79Tractor SC C18 R

$17,248

$28,644

80Tractor DC C18 HH

$4,353

$10,493

81 Tractor DC C17 R

$12,565

$6,309

82Tractor DC C18 R

$22,520

$13,737

83 Tractor DC C17 U

$12,565

$6,309

84Tractor DC C18 U

$22,520

$13,737

85B Transit C18 MP

$14,172

$7,123

86B Transit C16-7 MP

$8,363

$4,178

87B Transit C18 U

$14,172

$7,123

88B Transit C16-7 U

$8,363

$4,178

89T Utility C18 MP

$2,787

$1,702

90T Utility C18 R

$2,787

$1,794

91T Utility C16-7 MP

$5,138

$2,079

92T Utility C16-7 R

$5,138

$2,317

93T Utility C14-5 MP

$5,138

$1,353

94T Utility C12b-3 MP

$2,351

$642

95T Utility C14-5 R

$5,138

$1,500

96T Utility C12b-3 R

$5,138

$1,500

97T Utility C18 U

$2,787

$1,614

98T Utility C16-7 U

$5,138

$1,885

99T Utility C14-5 U

$5,138

$1,227

100T Utility C12b-3 U

$2,351

$583

101 Tractor DC C18 U

$2,480

$4,103

2.4.4.1 Maintenance and Repair

Data on real-world maintenance and repair costs for heavy-duty BEVs is limited due to
limited heavy-duty BEV technology adoption today. We expect the overall maintenance costs to

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be lower for heavy-duty BEVs than a comparable ICE vehicle for several reasons. First, an
electric powertrain has fewer moving parts that accrue wear or need regular adjustments. Second,
BEVs do not require fluids such as engine oil or DEF, nor do they require exhaust filters to
reduce particulate matter or other pollutants. Third, the per-mile rate of brake wear is expected to
be lower for BEVs due to regenerative braking systems. Several literature sources propose
applying a scaling factor to diesel vehicle maintenance costs to estimate BEV maintenance
costs.93'94'95 We followed this approach and applied a repair cost scaling factor of 0.71 to the
maintenance and repair costs for diesel-fueled ICE vehicles that are shown in Table 2-29. The
0.71 scaling factor is based on an analysis from Wang et al. 2022, that estimates a future BEV
HD vehicle would have a 29 percent reduction compared to a diesel-powered HD vehicle.96

In our payback analysis in HD TRUCS, we did not account for potential diesel engine rebuild
costs for ICE vehicles, potential replacement battery costs for BEVs, or potential replacement
fuel cell stack costs for FCEVs because our payback analysis typically covers a shorter period of
time than the expected life of these components. Typical battery warranties being offered by HD
BEV manufacturers range between 8 and 15 years today.97 A BEV battery replacement may be
practically necessary over the life of a vehicle if the battery deteriorates to a point where the
vehicle range no longer meets the vehicle's operational needs. We believe that proper vehicle
and battery maintenance and management can extend battery life. For example, manufacturers
can utilize battery management system to maintain the temperature of the battery98 as well active
battery balancing to extend the life of the battery.99'100 Likewise, pre-conditioning has also shown
to extend the life of the battery as well.101 Furthermore, research suggests that battery life is
expected to improve with new batteries over time as battery chemistry and battery charging
strategies improve, such that newer MY BEVs will have longer battery life.

2.4.4.2 Annual Electricity Use Costs

The annual electricity cost is a function of the electricity price, daily energy consumption of a
BEV, and number of operating days in a year. In HD TRUCS, we used DOE EIA's AEO 2022
reference case commercial electricity end-use price projection, as shown in Table 2-50.102 Most
HD vehicles are commercial vehicles. Therefore, we selected this value, instead of the
transportation end use prices in AEO, because the transportation end use prices in AEO are
similar to prices for the residential sector, which implies they may be more relevant to light-duty
vehicle charging than to commercial truck charging.

Table 2-50 Price of Electricity (2021$)

2027

2028

2029

2030

2031

2032

cents/kWh

10.63

10.65

10.67

10.70

10.69

2.5 Fuel Cell Electric Vehicle Technology

We considered HD FCEVs for select applications that travel long distances and/or have heavy
loads. Our analysis in HD TRUCS evaluates a FCEV as having similar components as a BEV
plus a fuel cell and an onboard hydrogen storage tank, with variations in the sizing of key
components. Rather than focusing on depot hydrogen fueling infrastructure costs that would be

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incurred upfront, we included infrastructure costs in our per-kilogram retail price of hydrogen.xlvi
This approach is consistent with the method we use in HD TRUCS for ICE vehicles, where the
equivalent diesel fuel costs are included in the diesel fuel price instead of accounting for the
costs of fuel stations separately.

To compare diesel and heavy-duty FCEV technology costs and performance, this section
explains how we characterize heavy-duty FCEVs based on the performance and use criteria in
Chapter 2.2. First, we determined the size of key FCEV components based on power
requirements and the hydrogen fuel amount required to meet the energy and daily operational
needs of each vehicle, and projected energy and fuel use for each FCEV application (kWh/mi) on
an annual basis. Then, we estimated upfront DMC of FCEV components. Finally, we projected
relevant operational costs, annualized over a 10-year period. Table 2-51 shows the technical
properties for eight vehicle types that travel long distances and/or have heavier loads (e.g., for
duty cycles where the volume or weight of a BEV battery may impact payload).xlv" The FCEV
properties analyzed in HD TRUCS as part of the technology package for the proposed standard
include peak power output of the fuel cell stack and e-motor, battery energy, hydrogen fuel tank
capacity, daily hydrogen fuel use, and hydrogen fuel tank volume.

Table 2-51 Technical Properties of the FCEV for MY 2032

Vehicle ID

Fuel Cell Stack Peak Power
(kW)

E-Motor
Peak Power
(kW)

Battery
Energy
(kWh)

H2 Fuel Tank
Capacity (kg)

Daily H2
Fuel Use
(kg)

17B Coach C18 R

204.1

339

28.1

31.22

14.34

18B Coach C18 MP

204.1

339

28.1

31.22

14.34

78Tractor SC C18 MP

181.3

568

80.6

48.62

20.70

79Tractor SC C18 R

181.3

568

74.5

66.78

43.38

80Tractor DC C18 HH

246.5

1030

148.0

31.66

15.92

81 Tractor DC C17 R

127.4

384

42.2

21.04

10.05

82Tractor DC C18 R

176.9

554

71.4

41.79

21.96

84Tractor DC C18 U

176.9

554

71.4

41.79

21.96

2.5.1 Fuel Cell Electric Vehicle Component Sizing

We determined the e-motor, fuel cell stack, and battery pack sizes necessary to meet the
power requirements for each of the eight FCEVs represented in HD TRUCS, as described in the
following subsections. We also estimated the size of the onboard fuel tank needed to store the
energy, in the form of hydrogen, required to meet typical range and duty cycle needs. Finally, the
sized components were then used to determine the cost of these vehicles.

2.5.1.1 Component Sizing Based on Power Needs

2.5.1.1.1 E-Motor

As discussed in Chapter 2.4.1.2, the e-motor is part of the electric drive system that converts
the electric power from the battery or fuel cell into mechanical power to move the wheels of the

xlvl Retail price of hydrogen is the total price of hydrogen when it becomes available to the end user, including the
costs of production, distribution, storage, and dispensing at a fueling station.

xlvn This does not mean that a BEV with large battery weight and volume is not technically feasible. Rather, this is
an acknowledgement that as battery size increase, cost is likely to increase, which can affect payback.

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vehicle. In HD TRUCS, the e-motor was sized for a FCEV like it was sized for a BEV (see
Chapter 2.4.1.2)—to meet peak power needs of a vehicle, which is the maximum requirement to
drive the ARB transient cycle, meet the maximum time to accelerate from 0 to 30 mph, meet the
maximum time to accelerate from 0 to 60 mph, and maintain a set speed up a six-percent grade.
Additional power was added to account for e-motor efficiency losses using the same e-motor
efficiency losses calculated and applied for BEVs, as discussed in Chapter 2.4.1.1.3.

2.5.1.1.2 Fuel Cell Stack

Vehicle power in a FCEV comes from a combination of the fuel cell stack and the battery
pack. The FC stack behaves like the internal combustion engine of a hybrid vehicle, converting
chemical energy stored in the hydrogen fuel into useful work. The battery is charged by power
derived from regenerative braking, as well as excess power from the FC stack. Some FCEVs are
designed to solely rely on the fuel cell stack to produce the necessary power, with the battery
exclusively used to capture energy from regenerative braking. Other FCEVs are designed to store
more energy in a battery to meet demand during situations of high-power need.xlv111'103

While much of FCEV design is dependent on the use case of the vehicle, manufacturers also
balance the cost of components such as the FC stack, the battery, and the hydrogen fuel storage
tanks. For the purposes of this HD TRUCS analysis, we focused on proton-exchange membrane
(PEM) fuel cells that use batteries with energy cells (described in Chapter 1.7.2), where the fuel
cell and the battery were sized based on the demands of the vehicle. In HD TRUCS, the fuel cell
stack was sized either to reach the 90th percentile of power required for driving the ARB
transient cycle or to maintain a constant highway speed of 75 mph. The 90th percentile power
requirement was used to size the fuel cells of vocational vehicles. For sleeper and day cabs, the
fuel cell was sized using the power required to drive at 75 mph with 80,000-pound gross
combined vehicle weight (GCVW).

2.5.1.1.3 Battery Pack

For FCEVs, HD TRUCS considered the use of batteries with energy cells rather than power
cells in the MY 2027-2032 timeframe. Energy cell batteries are less expensive to manufacture
than power cell batteries.xllx'104

In HD TRUCS, the battery power accounts for the difference between the power demand of
the e-motor at any moment and the maximum power output of the fuel cell stack. We sized the
battery to meet these power needs in excess of the fuel cell stack's capability only when the fuel
cell cannot provide sufficient power. In our analysis, the remaining power needs are sustained for
a duration of 10 minutes (e.g., to assist with a climb up a steep hill).

2.5.1.2 Onboard Hydrogen Storage Tank Sizing Based on Energy Needs

A FCEV is re-fueled like a gasoline or diesel-fueled vehicle. We determined the capacity of
the onboard hydrogen energy storage system using an approach like the BEV methodology for

xlvm Note that ANL's analysis defines a fuel cell hybrid EV as a battery-dominant vehicle with a large energy battery
pack and a small fuel cell, and a fuel cell EV as a fuel cell-dominant vehicle with a large fuel cell and a smaller
power battery. Ours is a slightly different approach because we consider a fuel cell-dominant vehicle with a battery
with energy cells. We took this approach because energy cell batteries are less expensive to manufacture than power
cell batteries.

x1k Generally, the cost of energy and power batteries are ratioed using the "power-to-energy" ratio.

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battery pack sizing in Chapter 2.4.1.1, but we based the amount of hydrogen needed on the daily
energy consumption needs of a FCEV.

Daily energy consumption is a summation of ZEV baseline energy and powertrain-specific
energy. A detailed description of ZEV baseline energy, which includes the energy used at the
axle to move the vehicle, regenerative braking, and PTO load, can be found in Chapter 2.2.2.1.
The powertrain-specific energy demand includes energy consumption associated with the fuel
cell stack, including energy used for HVAC and battery conditioning.

The ZEV baseline energy loads from Chapter 2.2.2 and the powertrain-specific energy loads
are reported in terms of kWh/mi, which was converted into kWh/day using the daily sizing
VMT. This daily energy consumption was then used to size the hydrogen fuel tank and
eventually estimate its cost. Since literature frequently provides cost of a hydrogen fuel tank in
terms of $ per kg of hydrogen, to determine the hydrogen tank size, we converted the energy
demand of each vehicle in HD TRUCS into weight of hydrogen needed.

We converted FCEV energy consumption (kWh) into hydrogen weight using an energy
content of 33.33 kWh per kg of hydrogen. In our analysis, 95 percent of the hydrogen in the tank
("usable H2") can be accessed. This is based on targets for light-duty vehicles, where a 700-bar
hydrogen fuel tank with a capacity of 5.9 kg has 5.6 kg of usable hydrogen.105 Furthermore, we
added an additional 10 percent to the tank to avoid complete depletion of hydrogen from the
tank.

2.5.1.2.1 Fuel Cell Stack Efficiency

To avoid undersizing the fuel cell, we apply efficiency values to account for losses that take
place before the remaining energy arrives at the axle. The same battery and inverter efficiencies
from Table 2-38 were used for the FCEV calculations. Fuel cell stack efficiency losses are due to
the conversion of onboard hydrogen to electricity. The DOE technical targets for Class 8 long-
haul tractor-trailers are to reach 68 percent peak efficiency by around 2030 (i.e., this is the
interim target; the ultimate target is to reach 72 percent efficiency).1'106 Table 2-52 shows the fuel
cell efficiency values that we used for MYs 2027-2032 in HD TRUCS, which are slightly more
conservative yet include expected improvements over time. We averaged the high-tech peak
efficiency estimates with low-tech peak efficiency estimates from ANL's 2022 Autonomie107 for
2025, 2030, and 2035 for available vehicle types. We then linearly interpolated these averaged
values to calculate values for each year.

Table 2-52 FCEV Fuel Cell Efficiencies for MY 2027-2032

Component

2027

2028

2029

2030

2031

2032

Fuel Cell

64.5%

66.0%

More information on ambient temperature impact on powertrain-specific energy demand can
be found in the following section.

2.5.1.2.2 HVAC and Battery Conditioning

1 According to DOE, ultimate targets are "based on 2050 simple cost of ownership assumptions and reflects
anticipated timeframe for market penetration".

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Fuel cell stacks produce excess heat during the conversion of hydrogen to electricity, like an
engine during combustion. This excess heat can be used to heat the interior cabin of the vehicle.
In HD TRUCS, no additional energy consumption is applied to FCEVs for heating operation,
and we already accounted for the energy loads due to ventilation in the axle loads. Therefore, for
FCEV energy consumption, we only include additional energy requirements for air
conditioning.11 As described in Chapter 2.4.1.1.1, we assigned a power demand of 3.32 kW for
powering the air conditioner on a Class 8 bus. The HVAC loads are then scaled by the cabin
volume for other vehicle applications in HD TRUCS and applied to the VMT fraction that
requires cooling.

Since the batteries in FCEVs have the same characteristics as batteries for BEVs, for battery
conditioning, we used the methodology described in Chapter 2.4.1.1.2 for BEVs to estimate the
energy consumption of the battery.

2.5.2 FCEV Components Costs

FCEVs and BEVs include many of the same components such as a battery pack, e-motor,
power electronics, gearbox unit, final drive, and electrical accessories. We assume these
components will have similar costs across vehicles used for the same applications; for detailed
descriptions of these components, see Chapter 2.4.3. In this subsection, we present the costs for
components for FCEVs that are different from a BEV. These components include the fuel cell
stack and hydrogen fuel tank. The same energy cell battery costs used for BEVs are used for
FCEVs, but the battery size of a comparable FCEV is smaller.108 Table 2-53 shows the
component level and total powertrain direct manufacturing costs for the eight FCEVs for MY
2032, which are described in more detail in the following subsections.

Table 2-53 Direct Manufacturing FCEV Costs and IRA Tax Credit for MY 2032 ($2021)

Vehicle ID

E-Motor

H2 Fuel

Battery

Power

Gearbox

Final

FCEV

Stack

($/unit)

Tank

with

Elec

($/unit)

Drive

PT Cost

($/unit)

IRA
Credit
($/unit)

($/unit)

($/veh)

17B Coach C18 R

$37,804

$5,080

$19,106

$2,896

$4,252

$1,831

$1,208

$72,177

18B Coach C18 MP

$37,804

$5,080

$19,106

$2,896

$4,252

$1,831

$1,208

$72,177

78Tractor SC C18 MP

$33,585

$8,523

$29,757

$8,322

$4,252

$3,798

$2,416

$90,653

79Tractor SC C18 R

$33,585

$8,523

$40,876

$7,686

$4,252

$3,798

$2,416

$101,135

80Tractor DC C18 HH

$45,664

$15,451

$19,376

$15,275

$4,252

$3,203

$2,416

$105,637

81 Tractor DC C17 R

$23,605

$5,758

$12,877

$4,357

$4,252

$1,922

$2,416

$55,187

82Tractor DC C18 R

$32,759

$8,302

$25,576

$7,369

$4,252

$3,810

$2,416

$84,484

84Tractor DC C18 U

$32,759

$8,302

$25,576

$7,369

$4,252

$2,705

$2,416

$83,380

11 We assume that FCEVs use waste heat from the fuel cell for heating, and that ventilation operates the same as it
does for an ICE vehicle.

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2.5.2.1 Fuel Cell Stack Costs

The fuel cell stack is the most expensive component of a heavy-duty FCEV. Fuel cells for the
heavy-duty sector are expected to be more expensive than fuel cells for the light-duty sector
because they operate at higher average continuous power over their lifespan, which requires a
larger fuel cell stack size, and because they have higher durability requirements (i.e., technology
targets are for 25,000- to 30,000-hours for a truck versus 8,000 hours for cars).110

Projected costs vary widely in the literature. They are expected to decrease as manufacturing
matures. Larger production volumes are anticipated as global demand increases for fuel cell
systems for HD vehicles, which could improve economies of scale.111 Costs are also anticipated
to decline as durability improves, which could extend the life of fuel cells and reduce the need
for parts replacement.112 Burke et. al compared estimates from the literature and chose values of
$240/kW in 2025 for a high case in their analysis, based on 1,000 heavy-duty fuel cell units
produced per year, and $145/kW for both a low case in 2025 and a high case in 2030, based on
3,000 units produced per year.113

Ballard, a fuel cell and clean energy provider, projected a steady decline in fuel cell system
price (i.e., not cost) throughout the decade, even at low volume. For fuel cell buses, they project
prices of around $600/kW in 2029. They cited purchase cost and parts maintenance and
replacement as factors affecting price.114

The interim DOE cost target for Class 8 tractor-trailer fuel stacks is $80/kW by 2030. Their
ultimate target is $60 per kW in 2050,111 set to ensure that costs are comparable to those of
advanced diesel engines and other factors. These targets assume 100,000 units per year
production volume. They pointed to analysis that suggests that 2019 costs at a manufacturing
volume of 1,000 units per year were around $190 per kW.115 In BEAN model updates, ANL
estimated a range based on vehicle type of between $1556 per kW and $174 per kW in 2025, and
from $65 per kW to $99 per kW by 2035.116

A Sharpe and Basma meta-study of other reports found 2025 costs ranging from $750/kW to
$50/kW. The authors stated that they expect fuel cell costs to drop by about 30 percent between
2025 and 2030 due to manufacturer learning, improved materials and performance, and
economies of scale.117 We decided to use this source because it was the most comprehensive
review of the literature at the time of the HD TRUCS analysis. Like the approach we took for
BEV battery costs, we averaged the 2025 cost values from the Sharpe and Basma meta-study,
averaged the 2030 values, and then linearly interpolated to get MY 2027 values and adjusted to
2021$; we then applied the learning curve shown in DRIA Chapter 3.2.1 to calculate MY 2028-
2032 values. The resulting fuel cell stack DMCs are shown in Table 2-54.1111

Table 2-54 HD Fuel Cell Stack Direct Manufacturing Costs (2021$)

2027

2028

2029

2030

2031

2032

111 According to DOE, ultimate targets are "based on 2050 simple cost of ownership assumptions and reflects
anticipated timeframe for market penetration".

lm IRA section 13502 provides tax credits for 10 percent of the cost of producing applicable critical materials,
including those found in fuel cells (providing that the minerals meet certain specifications), when such components
or minerals are produced in the United States. We did not include a detailed cost breakdown of fuel cells
quantitatively in our analysis, but the potential impact of the tax credit on fuel cells may be significant because
platinum (an applicable critical mineral commonly used in fuel cells) is a major contributor to the cost of fuel cells.

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$/kW

242

223

210

200

192

185

2.5.2.2 Hydrogen Fuel Tank Costs

Hydrogen storage cost projections also vary widely in the literature. Sharpe and Basma
reported costs ranging from as high as $1,289 per kg to $375 per kg of usable hydrogen in 2025.
They expect hydrogen tank costs to drop by 21 percent between 2025 and 2030 due to lighter
weight and lower cost carbon fiber-reinforced materials, technology improvements, and
economies of scale.118

The interim DOE target for Class 8 tractor-trailers is $300 per kg of hydrogen by 2030. Their
ultimate longer-term technology target is $266 per kg (2016$) by 2050. They include all balance
of plant components necessary to support the tank and assume a production volume of 100,000
tanks per year. They point to analysis that suggests that 2019 costs for 700-bar tanks at a
manufacturing volume of 1,000 tanks per year were roughly $1,200 per kg.119 For reference, the
Kenworth "beta" fuel cell truck holds six 10-kg hydrogen storage tanks at 700 bar.1211121

Like the approach we took for battery and fuel cell stack costs, we decided to use the Sharpe
and Basma paper for costs because it was the most comprehensive review of the literature at the
time of the HD TRUCS analysis. We averaged all of the 2025 cost values in the Sharpe and
Basma meta-study, averaged all of the 2030 values, and then linearly interpolated to determined
the MY 2027 value, adjusted to 2021$. We applied the learning curve shown in DRIA Chapter
3.2.1 to calculate MY 2028-2032 values. The hydrogen fuel tank DMCs are shown in Table
2-55.

Table 2-55 Hydrogen Fuel Tank Direct Manufacturing Costs (2021$)

MY 2027

MY 2028

MY 2029

MY 2030

MY 2031

MY 2032

$/kg H2

801

738

694

660

634

612

2.5.2.3 Vehicle Tax Credits

We applied the IRA section 13403 vehicle tax credit to FCEVs in HD TRUCS exactly how
we applied it to BEVs, as described in Chapter 2.4.3.5.

2.5.3 FCEV Operating Costs

The annual operating cost for FCEVs is the annual hydrogen fuel price plus the maintenance
and repair cost. Chapter 2.5.3.1 discusses hydrogen fuel price and how the annual hydrogen cost
of operating a FCEV is computed, and Chapter 2.5.3.2 discusses maintenance and repair costs
for FCEVs.

Table 2-56 FCEV Operating Costs for a MY 2032 Vehicle (2021$)

Vehicle ID

Annual FCEV M&R
($/year)

Annual Hydrogen Cost
($/year)

17B Coach C18 R

$ 17,432

$ 14,343

18B Coach C18 MP

$ 17,432

$ 14,343

78Tractor SC C18 MP

$ 8,676

$ 20,696

79Tractor SC C18 R

$ 18,220

$ 43,384

80Tractor DC C18 HH

$ 4,598

$ 15,917

191

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Vehicle ID

Annual FCEV M&R
($/year)

Annual Hydrogen Cost
($/year)

81 Tractor DC C17 R

$ 13,272

$ 10,052

82Tractor DC C18 R

$ 23,789

$ 21,960

84Tractor DC C18 U

$ 23,789

$ 21,960

2.5.3.1 Annual Hydrogen Fuel Price

For the purposes of the IID IRUCS analysis, we made simplifying assumptions regarding
how hydrogen will be priced for public and private fleet purchasers. Rather than focusing on
depot hydrogen fueling infrastructure costs that would be incurred upfront, we included
infrastructure costs in our per-kilogram retail price of hydrogen. We used a retail price of
hydrogen, which is the total price of hydrogen when it becomes available to the end user,
including the costs of production, distribution, storage, and dispensing at a fueling station. This
assumes that station capital costs are amortized within the price per kilogram of hydrogen. This
approach is consistent with the method we use in HD TRUCS for ICE vehicles, where the
equivalent diesel fuel costs are included in the diesel fuel price instead of accounting for the
costs of fuel stations separately.

We acknowledge that this market is still emerging and that hydrogen fuel providers will likely
pursue a diverse range of business models. For example, some businesses may sell hydrogen to
fleets through a negotiated contract rather than at a flat market rate on a given day. Others may
offer to absorb the infrastructure development risk for the consumer, in exchange for the ability
to sell excess hydrogen to other customers and more quickly amortize the cost of building a
fueling station. FCEV manufacturers may offer a "turnkey" solution to fleets, where they provide
a vehicle with fuel as a package deal. These uncertainties are not reflected in our hydrogen price
estimates presented in the DRIA.

As discussed in Chapter 1.3.2 and 1.8, large incentives are in place to reduce the price of
hydrogen production, particularly from electrolytic sources. In June 2021, DOE launched a
Hydrogen Shot goal to reduce the cost of renewable hydrogen production by 80 percent to $1 per
1 kilogram in 1 decade. The BIL and IRA included funding for several hydrogen programs to
accelerate progress towards the Hydrogen Shot and jumpstart the hydrogen market in the United
States.

For example, the BIL requires development of a National Clean Hydrogen Strategy and
Roadmap. In September 2022, DOE released a draft of a holistic plan that shows how low-GHG
hydrogen can help reduce emissions throughout the country by about 10 percent by 2050 relative
to 2005 levels. Figure 2-9 includes a snapshot of hydrogen cost status at low volume (light
green) and modeled costs at high-volume manufacturing levels (dark green) compared to
Hydrogen Shot goals (circles).122

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Fuel cell R&D

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IRA hydrogen production tax credit and assuming the use of utility-scale solar to produce
hydrogen.130 McKinsey projected green hydrogen costs of roughly $1.30-2.30 per kg in 2030,
produced using alkaline electrolyzers. Their analysis did not mention the IRA. It showed lower
costs for blue and grey hydrogen in 2030 before green hydrogen out-competes both by around
2040.131 An ICCT estimate of average hydrogen production costs in 2030 is closer to $3.10 per
kg, but their analysis did not consider IRA impacts.132

According to the Hydrogen Council, increasing the scale and rate of use of hydrogen across
sectors could substantially reduce the costs of local distribution. As trucking capacity increases
and the use, size, and density of refueling stations increases, equipment manufacturing costs
could decline. For example, they suggest that 2020 distribution costs of about $5-6/kg could
decline by about 80 percent to get to $1-1.50 per kg in 2030.133 A 2018 DOE document details
similar opportunities to reach $2 per kg in distribution and dispensing costs. In addition to
learning and economies of scale associated with scaled use, they suggest that potential research
and development advancements related to the efficiency and reliability of components could help
meet related DOE price targets.134

In HD TRUCS, we computed the annual fuel cost to operate a FCEV using the daily
operational cost as a function of the price of hydrogen, daily hydrogen consumption of a FCEV,
and number of operating days in a year (i.e., 250). The hydrogen prices we used in Table 2-57
for 2027-2032 are based on the Liftoff Report, which considers the IRA, and ANL BEAN
values, which are the same for low-, medium-, and high-tech scenarios.135 We believe this is
appropriate considering the substantial federal investment in hydrogen production (see DRIA
1.3.2) and the additional lead time to develop hydrogen infrastructure. We converted $ per kg
estimates for 2025 and 2030 (included in BEAN) to $ per kg by assuming that 1 gallon of diesel
is equivalent to 1.116 kg of hydrogen, based on a lower heating value. We rounded up to the
nearest $0.50 increment given the uncertainty of projections, and then interpolated for 2027 to
2029. Prices for 2030 and beyond are held constant in BEAN and in HD TRUCS.

Table 2-57 Price of Hydrogen for CY 2027-2032 (2021$)

2027

2028

2029

2030

2031

2032

$/kg H2

6.10

5.40

4.70

4.00

2.5.3.2 Maintenance and Repair

Like BEVs, data on real-world maintenance and repair costs for heavy-duty FCEVs is limited.
We expect the overall maintenance costs to be lower for a heavy-duty FCEV than a comparable
diesel- fueled ICE vehicle for several reasons. First, a FCEV powertrain has fewer moving parts
that accrue wear or need regular adjustments. Second, FCEVs do not require regular replacement
of certain fluids such as engine oil, nor do they require exhaust filters to reduce particulate matter
and other pollutants. Third, the per-mile rate of brake wear is expected to be lower for FCEVs
due to regenerative braking systems.

Fuel cell vehicles share many BEV components, with fuel cell vehicles also having fuel cell
stacks and hydrogen tanks; based on this, it is reasonable to assume that, since a FCEV has more
components than a BEV (e.g., a fuel cell and a hydrogen storage tank), a FCEV will have
slightly higher maintenance and repair costs than a BEV. Several literature sources propose
applying a scaling factor to diesel vehicle maintenance costs to estimate FCEV maintenance

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costs.136'137'138 We followed this approach and applied a repair cost scaling factor of 0.75 to the
maintenance and repair costs for diesel-fueled ICE vehicles that are shown in Table 2-29 This
scaling factor is slightly higher than the BEV scaling factor of 0.71. The 0.75 FCEV scaling
factor is based on an analysis from Wang et al. 2022, that estimates a future FCEV HD vehicle
would have a 25 percent reduction compared to a diesel-powered HD vehicle truck.139

Consistent with our approach for ICEs and BEVS, we did not include the costs for fuel cell
stack replacement within our analysis because it would occur beyond the 10-year assessment
period considered in the analysis (see Chapter 2.2.1.1.3).lvi

2.6 BEV Charging Infrastructure

Charging infrastructure will be needed to support the growing fleet of heavy-duty electric
vehicles. This section describes how we accounted for costs associated with charging
infrastructure in our analysis of heavy-duty BEV technology feasibility and adoption rates for
MYs 2027 through 2032.

2.6.1 Scope

As discussed in Chapter 1, we anticipate future charging infrastructure will include a
combination of depot charging (charging infrastructure installed in parking depots, warehouses,
and other private locations where vehicles are parked off-shift) and en-route charging (charging
infrastructure which provides additional electricity for vehicles during their operating hours).

For this analysis, we estimate infrastructure costs associated with depot charging to fulfill
each BEV's daily charging needs off-shift with the appropriately sized EVSE.lv" This approach
reflects our expectation that many heavy-duty BEV owners will opt to purchase and install
sufficient EVSE ports at or near the time of vehicle purchase to ensure operational needs are met.
Each depot charging station will be unique depending on the number of vehicles that the station
is designed to accommodate and their expected duty cycles, site conditions, and the charging
preferences of BEV owners. The subsequent sections describe how we considered these factors
and estimated the associated costs for each vehicle type in our analysis.

We acknowledge that not all BEV or fleet owners may choose to procure and install their own
EVSE. Even at depots, other business models may become more common if financially
advantageous. These could include lease agreements or charging as a service, in which a third-
party provider owns, operates, and maintains the charging equipment for a monthly (or other
recurring) fee. Given the uncertainty around uptake and costs of these alternatives at this early
market stage, we chose to instead account for the hardware and installation costs of depot EVSE
ports upfront in our analysis.

We also do not estimate upfront hardware and installation costs for public or other en-route
electric vehicle charging infrastructure because BEV charging needs are met with depot charging
in our analysis. As discussed in Chapter 1 of this document, we anticipate that a variety of public
and private funding—including Federal investments under the BIL and the IRA, and funding
from states, automakers, charging providers, utilities, and others—will help meet future charging

lvl The interim target fuel cell system lifetime for a Class 8 tractor-trailer is 25,000 hours, which is equivalent to
more than 10 years if a vehicle operates for 45 hours a week for 52 weeks a year.

lvu We sized EVSE to meet vehicles' daily electricity consumption (kWh/day) based on the 90th percentile VMT.

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infrastructure needs. (See Chapter 1.6.2.2 for some examples of private sector investments to
deploy HD BEV infrastructure along highways and other publicly accessible locations.)

2.6.2 EVSE Costs

Vehicle owners with return-to-base (or "depot") operations who choose to install privately-
owned charging equipment have many options from which to select. This includes AC or DC
charging, power levellvm, number of ports and connectors, connector type(s), communications
protocols, and additional features such as vehicle-to-grid capability (which allows the vehicle to
supply energy back to the grid). Many of these selections will impact EVSE hardware and
installation costs. For example, an ICCT paper found that hardware costs more than doubled
between networked and non-networkedllx Level 2 EVSE ports (with networked equipment
costing more).140 Among networked EVSE with one or two ports per pedestal, ICCT found a
roughly 10 percent difference in per-port hardware costs.144

Power level of the EVSE is one of the most significant drivers of cost. While specific cost
estimates vary across the literature, higher-power charging equipment is typically more
expensive than lower-power units. For example, ICCT estimated hardware costs for a 350 kW
DCFC port to be five times higher than for a 50 kW port.144 For this reason, we have chosen to
evaluate infrastructure costs separately for four different, common power levels: AC Level 2
(19.2 kW) and 50 kW, 150 kW, and 350 kW DCFC.lx'lxi

Installation costs typically include labor and supplies, such as wire, conduit, and other
hardware required for installation that is not supplied with the EVSE hardware purchase.
Installation costs may also be incurred for permitting, taxes, and any upgrades or modifications
to the on-site electrical service. These costs, especially those for labor and permitting can vary
widely by region.141 Costs also vary by site conditions. The amount of land preparation and
trenching needed will depend on the distance from where vehicles are parked (and the charging
equipment is located) and the electrical panel.142 For example, a recent study found that average
Level 2 installation costs at commercial locations increased by $20 for each extra foot of
distance between the EVSE and power source.143 Another key factor is how many EVSE ports
are installed. ICCT estimated that on a per-port basis, installation costs for 150 kW ports were
about 2.5 times higher when only one port is installed compared to 6-20 per site.144 And as with
hardware costs, installation costs may rise with power levels.

To reflect the diversity in anticipated depot infrastructure costs, we consider a range of
hardware and installation costs for each charging type in our analysis. For DC fast charging, we
sourced these from a 2021 study specific to heavy-duty electrification at charging depots. The

lvm Charging types are described in Chapter 1.6.1.2

llx Networked chargers are equipped with communications hardware such as WiFi or cellular.
k Level 2 charging is available at a range of power levels. For simplicity, we have selected the upper end of the
range to reflect our expectation that some heavy-duty fleets may opt for this power level. However, we acknowledge
other fleets may find that lower-powered (e.g., 10 kW or 16.6 kW) Level 2 charging meets their needs and would
therefore be likely to have lower infrastructure costs. Other DCFC power levels between 50 kW and 350 kW may
also be available; this list is not intended to be comprehensive.

1x1 As noted in Chapter 1.6.1.2, even higher-power levels of DC fast charging (1 MW+) are under development, and
several studies have considered how such high-power EVSE could help meet future en-route and public charging
needs. We did not consider these to be as likely choices for depot charging and therefore did not include them in this
analysis.

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study estimated the cost for procuring and installing 50 kW EVSE to be $30,000-$82,000 per
port, the cost for 150 kW EVSE to be $94,000-$148,000 per port, and the cost for 350 kW
EVSE to be $154,000-$216,000 per port.lxii'145

Most of the literature on Level 2 EVSE costs is for power levels common for light-duty
vehicle charging. For example, the ICCT study previously discussed estimated hardware costs
for networked 6.6 kW ports to be about $3,000 with approximately another $2,000-$4,000 per
port for installation.146 We expect higher costs for higher-powered Level 2 charging equipment.
An RMI study showed a spread of hardware costs from $2,500 for a 7.7 kW charger to $4,900
for a 16.8 kW charger, with one outlier over $7,000 (for 14.4 kW).147 A guide by the Vermont
Energy Investment Corporation (VEIC), which engaged in an electric school bus pilot, estimates
that equipment and installation for high-powered Level 2 EVSE could range from $4,200 to over
$21,000.148 We selected a range of $10,000 to $20,000 per EVSE port for our analysis.

Table 2-58 summarizes the range of costs we considered for each charging type, adjusted to
2021 dollars.1x111

Table 2-58 Combined Hardware and Installation Costs, per EVSE Port (in 2021$)

Power level

Cost range

Level 2 (19.2 kW)

$10,541 - $21,082

DC-50 kW

$31,623 - $86,437

DC-150 kW

$99,086 - $156,008

DC-350 kW

$162,333 - $227,687

As discussed in Chapter 1.3.2, the IRA Section 13404 extends and modifies a federal tax credit
available for alternative fuel refueling property, including BEV charging equipment. See Chapter
2.6.5.2 for a discussion of how this tax credit may impact depot charging costs, and how we
considered it in our cost analysis.

2.6.3 Will costs change over time?

The hardware and installation costs shown above generally reflect present day values.
However, both could vary over time. For example, hardware costs could decrease due to
manufacturing learning and economies of scale. Recent studies by ICCT assumed a 3 percent
reduction in hardware costs for EVSE per year to 2030.149>150 By contrast, installation costs could
increase due to growth in labor or material costs. As noted above, installation costs are also
highly dependent on the specifics of the site including whether sufficient electric capacity exists
to add charging infrastructure and how much trenching or other construction is required. If fleet
owners choose to install charging stations at easier, and therefore, lower cost sites first, then
installation costs could rise overtime as stations are developed at more challenging sites. One of
the ICCT studies discussed above151 found that these and other countervailing factors could

1x11 Costs are expressed in 2019 dollars. We did not include the cost that may be incurred if a depot owner decides to
install a separate meter for EVSE. These costs ($1,200—5,000) are relatively small compared to EVSE
procurement and installation costs and would be even smaller on a per port basis if spread across multiple EVSE
ports.

1x111 Values in the literature are assumed to be 2019 costs.

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result in the average cost of a 150 kW EVSE port in 2030 being similar (~3 percent lower) to
that in 2021.

Due to the uncertainty on how costs may change over time, we have made the simplifying
assumption for this analysis to keep combined hardware and installation costs per EVSE port
constant.

2.6.4 Which charging equipment will fleet owners buy?

In the preceding section, we described infrastructure costs for four different charging types
that we think could be used for depot charging. To estimate the corresponding costs for each
vehicle type, we considered the type and number of chargers that different BEV owners may
buy.

The choice of charging equipment will be based on the needs and preferences of each BEV or
fleet owner. Fleet owners may work with OEMs, dealers, utilities, or charging equipment
suppliers to analyze their charging options based on duty cycle requirements of the fleet and site-
specific conditions of the depot, warehouse, or yard where EVSE will be installed. Some owners
will likely opt for the lowest-power or lowest-cost charger that is appropriate for the application.
Others may opt for higher-cost options. This could be due to preferences for certain equipment
brands, warranty contracts, durability, serviceability, or safety requirements, among other
features. Some fleets may also choose higher-power charging options than what is required to
prepare for future or additional vehicle purchases, resiliency, or evolving business needs.

For our analysis, we assumed BEV or fleet owners would opt for the lowest-cost charging
option that could be used to meet the vehicle's daily electricity consumption based on the 90th
percentile (or sizing) VMT (discussed in Chapter 2.2.1.2 and 2.4.1.1). Two key inputs include
(1) the amount of time a vehicle has to charge at the depot each day, and (2) whether more than
one vehicle can share charging equipment.

2.6.4.1 Available time for depot charging

How long a vehicle is off-shift and parked at a depot, warehouse, or other home base each day
is a key factor in determining what type of charging infrastructure could meet its needs. We
refer to this as depot "dwell time." This depot dwell time depends on a vehicle's duty cycle. For
example, a school bus or refuse truck may be parked at a depot in the afternoon and remain there
until the following morning whereas a transit bus may continue to operate throughout the
evening. Vehicles like long-haul trucks and motorhomes may not even return to a home base
location each day. Even for a specific vehicle, off-shift depot dwell times may vary between
weekends and weekdays, by season, or due to other factors that impact its operation.

The 101 vehicle categories in our analysis span a wide range of vehicle types and duty cycles,
and we expect their dwell times to vary accordingly. However, assigning specific depot dwell
times for each vehicle type is challenging due a lack of comprehensive data sets on parking times
and locations.

To get a first look of what an average depot dwell time might look like, we examined a
dataset of start and idle activity for 564 commercial vehicles that had been analyzed as a joint

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effort of EPA and NREL to inform EPA's MOVES model.l52Jxiv"153 The data includes engine
starts and engine off times over the period of data collection for each vehicle. Since location data
was not included, we used the longest soak length (defined as time between engine off and the
next start) each day as a rough proxy for depot dwell time and calculated an average depot dwell
time for each vehicle.lxv While most vehicles in the sample operated on diesel,lxvi we treated
these proxy dwell times as opportunities for when an electric vehicle with the same duty cycle
could be recharged.

Table 2-59 shows a summary of these values for seven vehicle categories, where we have
further averaged proxy dwell times for all vehicles of a given MOVES Source Type lD.lxv11 lxvm

Table 2-59 Average Proxy Dwell Times for Seven MOVES Vehicle Categories'51'51

MOVES
Source Type ID

Description

Sample Size

Avg Proxy Dwell
Time (hours)

Other Buses

11.8

Transit Buses

11.1

School Buses

18.8

Refuse Trucks

18.7

Single-Unit Short-Haul Trucks

149

15.8

Combination-Unit Short-haul Trucks

144

16.3

Combination-Unit Long-haul Trucks

195

11.5

Total

564

14.5

The average across all 564 vehicles was over 14 hours, with proxy dwell times for most of the
categories rounding to 12 hours or longer. However, these averages mask the significant
variation in vehicles' day-to-day operations; for example, a vehicle may be parked for multiple
days over a weekend or other periods of low activity and then operate for several days with
relatively short soak lengths. Fleet owners selecting charging equipment will need to ensure that
vehicles can be charged sufficiently to meet operational needs each day, rather than on an
average basis. We also note several limitations in the data itself that could result in the proxy
dwell times calculated here not being representative of the BEVs in our analysis. That includes a
lack of data on motorhomes and small samples sizes, particularly for buses and refuse trucks. In
addition, travel patterns and dwell times could vary based on geography, and this data set may
not be nationally representative. Given these low sample sizes and other limitations, we
determined that we do not have sufficient data to assign unique dwell times to the different

klv We used the "Combined Data" which includes data from NREL's Fleet DNA database as well as CE-CERT data
collected by the University of California, Riverside, specifically, the files "StartSoakEvents_final_all.csv" and
"MetaData_final_all. csv".

kv Soak lengths were assigned to the day they began, and the full soak period was considered (even if >24 hours).
Days in which no soak began were assigned a zero-soak length for the purpose of averaging. In a small number of
instances, the data set included negative soak lengths; these were treated as errors and not counted in averaging.
kvl The vast majority of the 564 vehicles were coded as operated on conventional diesel, five were coded as
operating on CNG, and 16 were coded as operating on either renewable or biodiesel.

kvn We gave each vehicle equal weight when averaging despite significant differences in data collection periods in
order to reflect the diversity of duty cycles in the sample.

kvm originai data set also includes six vehicles identified by MOVES Source Type ID 40. Since that source type
does not correspond to any of the 101 vehicle types in our analysis, we considered these to be out of scope and
excluded them from the sample.

kK See the spreadsheet "Depot Dwell Time.xlsx" in the docket.

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vehicle categories in our analysis, and instead made a simplifying assumption to apply one value
across all 101 vehicle types. We selected 12 hours as the off-shift depot dwell time assumed for
the purpose of selecting charging equipment at depots in our infrastructure cost analysis. As
noted above, the average proxy dwell times shown in Table 2-59 round to 12 hours or higher for
all categories but transit buses (which is at 11 hours). We plan to revisit this assumption in future
analyses.

2.6.4.2 How many vehicles will share EVSEports?

Charging infrastructure can be shared across multiple vehicles in a variety of ways. An EVSE
port with just one connector can be used sequentially by different vehicles. If those vehicles are
parked at the depot at different times of day, drivers may plug in when they park. If vehicles
have overlapping depot dwell times, employees may be tasked with swapping the connector
among vehicles—though this may have tradeoffs in terms of convenience and may not be
practical for all applications. Other EVSE ports are available for purchase with multiple
connectors allowing vehicles to charge sequentially without the need to swap connectors.154

Rated power can also be shared across EVSE ports by either decreasing the charging rate of
vehicles charging simultaneously or charging vehicles one after another.155 For example, a dual
port 150 kW DCFC unit could be configured to charge one vehicle at 150 kW or two vehicles at
75 kW. Some residential and commercial Level 2 charging equipment is also capable of power
sharing (e.g., the Tesla Gen 3 Wall Connector).156 This can be accomplished through either a
multi-connector charging unit, or use of multiple units on the same electrical circuit which
communicate to limit the total power being delivered.

Sharing charging equipment or power may be attractive to fleet owners as it can reduce the
upfront costs associated with procuring and installing EVSE at depots. And by spreading
infrastructure costs across multiple vehicles, per-vehicle EVSE costs can decline by 50 percent
or more. Of course, the decisions of whether to share EVSE ports and which types of sharing are
selected will depend on the specific situation and operational needs of the fleet. Vehicles that
operate across multiple shifts and have limited depot dwell time, irregular schedules, or
particularly high levels of power consumption may be poor candidates for sharing a port.
Conversely, applications with predictable schedules, appropriate duty cycles, and favorable
depot dwell times may find a cost benefit in shared charging.

In our analysis, we assume that up to two vehicles can share one DCFC port if there is
sufficient depot dwell time for both vehicles to meet their daily charging needs.lxx While fleet
owners may also choose to share Level 2 ports across vehicles, we have decided to
conservatively assign one EVSE port per vehicle. This reflects our expectation that sharing may
be more limited for Level 2 ports at least in the early years of HD BEV adoption given the
relatively long charging time and more limited potential upfront cost savings compared to
DCFC.

2.6.5 Other considerations

kx We note that for some of the vehicle types we evaluated, more than two vehicles could share a DCFC port and
still meet their daily electricity consumption needs. However, we choose to limit sharing to two vehicles pending
market developments and more robust depot dwell time estimates.

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2.6.5.1 Additional costs

While our analysis focuses on the hardware and installation costs for EVSE described above,
we acknowledge that additional upfront costs associated with depot charging could be incurred,
particularly for large BEV fleets or BEVs with high daily electricity consumption. For example,
some depot charging sites may require upgrades to the electricity distribution system to meet the
new or additional charging loads. While these needs and costs will be site specific, one recent
study estimated that loads of just 200 kW or higher could trigger the need for an onsite
distribution transformer, at an estimated cost between $12,000 and $175,000.157 New charging
loads of 5 MW or higher—likely only relevant for depots with many high-power DCFC ports—
could require more significant and costly distribution system upgrades such as those to feeder
circuits or breakers. As discussed in Chapter 1.6.4, there are a variety of approaches that could
reduce the need or scale of such upgrades, including factoring distribution system capacity into
station siting decisions, considering alternative charging solutions (e.g., mobile charging units or
standalone charging canopies with integrated solar generation) at sites that are particularly
challenging or cost-prohibitive, or managing charging load to limit the instantaneous demand on
the grid. In many cases, costs for some distribution system upgrades may be borne by utilities
rather than directly incurred by BEV or fleet owners whose costs we model in our analysis of
depot charging infrastructure; therefore, we do not include these costs in our analysis.

Additional depot charging costs could also be incurred based on the choices of the fleet
owner. For example, some fleet owners may opt to install battery energy storage or renewable
energy such as solar panels at charging stations. While these choices add upfront costs, fleet
owners can save on electricity costs over time. For example, by recharging BEVs from onsite
battery energy storage rather than directly from the grid, owners can reduce the amount of
electricity purchased during peak hours (since battery energy storage can be replenished during
off-peak periods). This can help fleet owners take advantage of lower-priced, time-of-use
electricity rates, where applicable. Onsite battery energy storage can also be used to avoid large
power draws from the grid, potentially reducing costly demand charges that are tied to peak
power.158 Installing solar panels or other onsite renewables can support these strategies while
also reducing the overall volume of electricity fleet owners need to purchase from utilities and
potentially reducing the need for distribution upgrades described above.

There is significant uncertainty about how many charging depots will incorporate these
technologies over time, and how the incorporation of these technologies could impact site costs.
The savings fleet owners may expect will also be highly variable based on local electricity rates
and the charging load of the site. However, we generally expect that many fleet owners who
choose to install onsite battery storage and renewables do so with the intent of recouping the
upfront capital costs through electricity cost savings. For these reasons, we do not include these
costs in our depot charging estimates.

2.6.5.2 Inflation Reduction Act and Other Federal Funding

As discussed in Chapter 1.3.2, the IRA Section 13404, "Alternative Fuel Refueling Property
Credit," extends and modifies (beginning in 2023) a federal tax credit available for alternative
fuel refueling property, including EV charging equipment. The tax credit is available through
2032. Pursuant to this provision, businesses may receive up to 30 percent of the costs associated
with procuring and installing EV charging equipment on properties located in low-income or
rural census tracts (subject to a total cap of $100,000 per item) if prevailing wage and

201

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apprenticeship requirements are met. Where applicable, this tax credit could significantly reduce
costs that BEV owners or EVSE providers incur for charging infrastructure. In addition, there are
a variety of federal funding programs, as discussed in Chapter 1.3.2, that may be used in part to
fund charging infrastructure for heavy-duty vehicles. Due to the complexity of analyzing the
combined potential impact of these provisions (including IRA programs for which
implementation guidance is not yet available) we have not directly accounted for these cost
savings in our depot charging analysis. However, to reflect our expectation that these programs
could significantly reduce the overall infrastructure costs paid by BEV and fleet owners for depot
charging, we are using the low end of our hardware and installation cost ranges, as shown in
Table 2-60, for each charging type. The final per-vehicle cost assumptions we used for each
charging type are summarized in Table 2-60.

Table 2-60 Combined Hardware and Installation EVSE Costs, per vehicle (in 2021$)

Cost—1

Cost—2

Charging Type

vehicle per

vehicles per

port

Level 2-19.2 kW

$10,541

DCFC-50 kW

$31,623

$15,812

DCFC—150 kW

$99,086

$49,543

DCFC-350 kW

$162,333

$81,166

Chapter 2.7.7 describes how we assigned these costs to each of the 101 vehicle types in our
analysis. The results are summarized in Table 2-61, which shows the charging type (designated
in the table by its power level) assigned to each vehicle ID, whether one or two vehicles are
assumed to share the EVSE port, and the final per vehicle EVSE cost (reflecting upfront
hardware and installation costs for depot charging).

Table 2-61 Summary of per vehicle EVSE costs for MY 2027 and 2032 (in 2021$)

Vehicle ID

Electricity
Consumption'5011
(kWh/day)

Charging Type
(kW)

Vehicles per
EVSE port

EVSE Cost
($/vehicle)

2027

2032

2027

2032

2027

2032

2027

2032

01V Amb C14-5 MP

$10,541

02V Amb C12b-3 MP

100

$10,541

03V Amb C14-5 U

$10,541

04V Amb C12b-3 U

$10,541

05T Box C18 MP

298

295

$31,623

06T Box C18 R

319

315

$31,623

07T Box C16-7 MP

201

199

$10,541

08T Box C16-7 R

227

224

$15,812

09T Box C18 U

276

273

$31,623

10T Box C16-7 U

208

205

$15,812

$10,541

1 IT Box C12b-3 U

111

110

$10,541

12T Box C12b-3 R

141

139

$10,541

13T Box C12b-3 MP

125

124

$10,541

14T Box C14-5 U

105

104

$10,541

15T Box C14-5 R

133

131

$10,541

kxl Electricity consumption based on 90th percentile daily VMT (or sizing VMT).

202

-------
Vehicle ID

Electricity
Consumption'5"11
(kWh/day)

Charging Type
(kW)

Vehicles per
EVSE port

EVSE Cost
($/vehicle)

2027

2032

2027

2032

2027

2032

2027

2032

16T Box C14-5 MP

118

117

$10,541

17B Coach C18 R

974

964

350

$81,166

18B Coach C18 MP

974

964

350

$81,166

19C Mix C18 MP

371

367

$31,623

20T Dump C18 U

360

356

$31,623

21T Dump C18 MP

383

379

$31,623

22T Dump C16-7 MP

362

358

$31,623

23 T Dump C18 U

360

356

$31,623

24T Dump C16-7 U

326

322

$31,623

25T Fire C18 MP

394

390

$31,623

26T Fire C18 U

373

369

$31,623

27T Flat C16-7 MP

201

199

$10,541

28T Flat C16-7 R

227

224

$15,812

29T Flat C16-7 U

179

178

$10,541

30Tractor DC C18 MP

502

497

$31,623

31 Tractor DC C16-7 MP

445

440

$31,623

32Tractor DC C18 U

502

497

$31,623

3 3 Tractor DC C16-7 U

445

440

$31,623

34T Ref C18 MP

413

409

$31,623

35T Ref C16-7 MP

464

459

$31,623

36T Ref C18 U

413

409

$31,623

37T Ref C16-7 U

464

459

$31,623

38RV C18 R

775

767

150

$49,543

39RV C16-7 R

824

815

350

$81,166

40RV C14-5 R

524

519

$31,623

41RV C12b-3 R

524

519

$31,623

42RV C18 MP

775

767

150

$49,543

43RV C16-7 MP

730

722

150

$49,543

44RV C14-5 MP

464

459

$31,623

45RV C12b-3 MP

464

459

$31,623

46B School C18 MP

171

169

$10,541

47B School C16-7 MP

168

166

$10,541

48B School C14-5 MP

124

123

$10,541

49B School C12b-3 MP

115

114

$10,541

5OB School C18 U

162

160

$10,541

5 IB School C16-7 U

168

166

$10,541

52B School C14-5 U

112

111

$10,541

53B School C12b-3 U

103

102

$10,541

54B Shuttle C14-5 MP

226

224

$15,812

55B Shuttle C12b-3 MP

217

215

$15,812

56B Shuttle C14-5 U

202

200

$10,541

57B Shuttle C12b-3 U

193

191

$10,541

58B Shuttle C16-7 MP

349

346

$31,623

59B Shuttle C16-7 U

313

309

$31,623

60S Plow C16-7 MP

125

124

$10,541

61S Plow C18 MP

337

334

$31,623

62S Plow C16-7 U

115

114

$10,541

63 S Plow C18 U

317

314

$31,623

64V Step C16-7 MP

225

222

$15,812

65V Step C14-5 MP

$10,541

203

-------
Vehicle ID

Electricity
Consumption'5"11
(kWh/day)

Charging Type
(kW)

Vehicles per
EVSE port

EVSE Cost
($/vehicle)

2027

2032

2027

2032

2027

2032

2027

2032

66V Step C12b-3 MP

118

117

$10,541

67V Step C16-7 U

200

198

$10,541

68V Step C14-5 U

$10,541

69V Step C12b-3 U

105

104

$10,541

70S Sweep C16-7 U

210

208

$15,812

71T Tanker C18 R

357

353

$31,623

72T Tanker C18 U

338

334

$31,623

73T Tanker C18 U

319

316

$31,623

74T Tow C18 R

573

567

150

$49,543

75T Tow C16-7 R

407

403

$31,623

76T Tow C18 U

507

502

$31,623

77T Tow C16-7 U

327

324

$31,623

78Tractor SC C17 R

1484

1468

350

$81,166

79Tractor SC C18 R

2036

2015

350

$162,333

80Tractor DC C18 HH

965

955

350

$81,166

81 Tractor DC C17 R

644

637

150

$49,543

82Tractor DC C18 R

1275

1261

350

$81,166

83Tractor DC C17 U

644

637

150

$49,543

84Tractor DC C18 U

1275

1261

350

$81,166

85B Transit C18 MP

611

605

150

$49,543

86B Transit C16-7 MP

656

649

150

$49,543

87B Transit C18 U

611

605

150

$49,543

88B Transit C16-7 U

656

649

150

$49,543

89T Utility C18 MP

162

160

$10,541

90T Utility C18 R

171

169

$10,541

91T Utility C16-7 MP

217

214

$15,812

92T Utility C16-7 R

241

239

$15,812

93 T Utility C14-5 MP

141

139

$10,541

94T Utility C12b-3 MP

$10,541

95T Utility C14-5 R

156

155

$10,541

96T Utility C12b-3 R

156

155

$10,541

97T Utility C18 U

154

152

$10,541

98T Utility C16-7 U

196

194

$10,541

99T Utility C14-5 U

128

126

$10,541

100T Utility C12b-3 U

$10,541

101 Tractor DC C18 U

470

465

$31,623

2.7 HD TRUCS Functionality

HD TRUCS is an extensive physics-based tool designed to project ZEV technology
feasibility, payback, and adoption rates in future model years. This chapter includes the
methodology and formulas used in the tool, with main topics and calculations organized
similarly to the structure of this chapter of the RIA. The ICE Tech tab is covered in Chapter 2.3,
the BEV Tech tab in Chapters 2.4 and 2.6, and the FCEV Tech tab in Chapter 2.5. The Payback
and Technology Penetration tabs are addressed in Chapters 2.7 and 2.8.

2.7.1 Baseline Energy and Fuel Consumption

204

-------
Energy consumption was calculated for 2027 using GEM with the physical parameters of a
ICE vehicle. (See Chapter 2.2 for more information on the GEM runs.) We converted the GEM
output of energy in kWh for each duty cycle to energy consumption per mile by dividing the
energy consumption for each regulatory type by the distance of each GEM duty cycle (see
2.2.2.1.2).

Each of the energy consumption calculations was then weighted by the appropriate weighting
factor for their respective regulatory classes and summed to provide us with the weighted energy
consumption of each regulatory class. GEM distance weighting and time weighting factors as
well as average speed during non-idle cycles may be found in Chapter 2.2.2.1.2. Furthermore,
GEM axle energy consumption includes air conditioning energy consumption; this value is
subtracted out and considered separately for BEV and FCEV technologies.

The calculation for weighted energy consumption for tractors of each regulatory class is in
Equation 2-land the vocational vehicle weighted energy consumption calculation is in Equation
2-2. Table 2-13 shows the results of the calculations.

Equation 2-1 Weighted Energy Consumption per Mile for Tractors

kWh

axle

-I

k,Whc*fc kWh

tract ' ' dc TYli

c=1

Where:

kWflaxle

= weighted energy consumption at the axle for tractors.

tract

kWhc = energy consumed during the appropriate test cycle, c.

fc = weighting factor for the appropriate test cycle, c, as shown in Table 2-12.

dc = the total driving distance for the indicated duty cycle, c, as shown in Table 2-11.

c = tractor drive cycles where 1 = ARB transient cycle, 2 = 55 MPH cruise or 3 = 65 MPH
cruise cycles.

= weighted energy consumption of air conditioning (AC) load.

Equation 2-2 Weighted Energy Consumption per Mile for Vocational Vehicles

205

-------
kWh

axle

voc Vmoving * (l fdrive fpark)

fdrive fpark) *

kWh

kWhc *fc _
* v

moving

fdrive * ^Wdrive fpark

c=1

* /cVKparfc

Where:

kWhaxle

= weighted energy consumption at the axle for vocational vehicles.

kWhc = energy consumed during the appropriate test cycle, c.

fc = weighting factor for the appropriate test cycle, c, shown in Table 2-12.

dc = the total driving distance for the indicated duty cycle, c, shown in Table 2-11.

c = vocational drive cycles where 1 = ARB transient cycle, 2 = 55 MPH cruise or 3 = 65
MPH cruise cycles

drive-idle and parked-idle fractions

vmoving = mean composite weighted driven vehicle speed, excluding idle operation, as shown
in Table 2-12, for Phase 2 vocational vehicles. For other vehicles, let vm0Ving = 1-

AC energy consumption at the axle is converted from AC load and using the appropriate
weighting factors, shown in Equation 2-3.

Equation 2-3 Duty Cycle Weighted Average Air Conditioning Energy Requirement

kWh

— 1 W x tc*fc

— kWAC *

ac dc

c—l

I-

mi
Where:

kWAC= Air conditioning load; 1.0 for LHD and MHD, and 1.5 for all other vehicles
tc = the total driving time in seconds for the respective cycles as shown in Table 2-11
fc = the weighting factors for the respective GEM duty cycles, shown in Table 2-12.
dc = the distance in miles, shown in Table 2-11.

c = GEM drive cycles where 1 = ARB transient cycle, 2 = 55 MPH cruise or 3 = 65 MPH
cruise cycles, shown in Table 2-11.

206

-------
Regenerative braking plays a large role in energy consumption of electric and fuel cell
vehicles, and we took this into account by calculating the distance-weighted percent of recovered
energylxx" from tractive energy for each regulatory class. To do this, we started with a model
developed in-house for hybrid vehicles and adjusted the input parameters to prevent the battery
capacity and state of charge from limiting the amount of recovered energy. We also limited
braking capacity to 90 percent of total braking power to allow for some use of the traditional
braking system. See Table 2-62 for input parameters.

Table 2-62 Input Parameters for Hybrid Vehicle Model

Vehicle Parameters

Input Values

Mass (kg)

Table 2-8 and Table 2-9

CdA (mA2)

Table 2-8 and Table 2-9

Crr (kg/t)

Table 2-8 and Table 2-9

Battery Size (kwh)

200

Pmax Regen (kW)

500

Battery SoC Min (%)

Battery SoC Max (%)

Hybrid System Efficiency (%)

Axle Efficiency (%)

Accessory Power driven by wheels (kW)

1.5

Hybrid Braking Power (% of total braking power)

We then calculated the road load power required for each drive cycle via Equation 2-4using
positive values for tractive power and negative values for braking power.

Equation 2-4 Road Load Power

/mVe * g* Crr pair * CdA * vc2 x

I / i/tz & " " I r iia C

:lc = T7T7T7: + n + ave

road lc y 100Q 2 ¦ ~ve —ve j 100Q

Where:

Proadlc = Road load power for each drive cycle, c
mve = mass of the vehicle (kg)
g = gravitational constant of 32.2 m/s2
Crr = tire rolling resistance (kg/ton)

CdA = drag area, m2pair = density of air at a constant value of 1.17 (kg/m3)

vc = velocity of the vehicle at each specific point of the drive cycle, c

aveh = acceleration of the vehicle at each specific point of the drive cycle

c = GEM drive cycles where 1 = ARB transient cycle, 2 = 55 MPH cruise or 3 = 65 MPH
cruise cycles, shown in Table 2-11.

kxn Recovered energy is amount of energy that is gained while driving an electric vehicle. It is gained in the form of
regenerative braking which is defined in footnote xxi.

207

-------
We were then able to calculate the regenerative braking power in Equation 2-6 using only the
negative values from hybrid available power in Equation 2-5 Negative Road Load Power.

Equation 2-5 Negative Road Load Power

Pneg_road\c Proadlc * P%brake * Vhyb * Vaxle facc

Where:

Pnegroad |c = available hybrid power for the appropriate cycle (kW).

P%brake = percent of braking power available to hybrid system, value is in Table 2-62.

Vhyb = hybrid system efficiency, shown in Table 2-62.

Vaxie = axle efficiency, shown in Table 2-62.

Pacc = accessory power driven by the wheels, shown in Table 2-62.

c = GEM drive cycles where 1 = ARB transient cycle, 2 = 55 MPH cruise or 3 = 65 MPH
cruise cycles, shown in Table 2-11.

Equation 2-6 Regenerative Braking Power

Pregen\c Pneg_road\c * Vhy * Vaxle

Where:

Pregen\c = regenerative braking power for each cycle

Pnegrod |c = available hybrid power for the appropriate cycle (kW).

r/hyb = hybrid system efficiency, value is in Table 2-62.

Vaxie = axle efficiency, value is in Table 2-62.

c = GEM drive cycles where 1 = ARB transient cycle, 2 = 55 MPH cruise or 3 = 65 MPH
cruise cycles, shown in Table 2-11.

Equation 2-7 Recovered Energy
kWhrec\c - _3600Q K Pregen |c)

Where:

kWhrec\c = recovered energy of the appropriate cycle (kWh)

208

-------
c = GEM drive cycles where 1 = ARB transient cycle, 2 = 55 MPH cruise or 3 = 65 MPH
cruise cycles, shown in Table 2-11.

Equation 2-8 Tractive Energy

kWhtract | CyC

36000

Where:

kWhtract\c = tractive energy of the appropriate cycle (kWh)

Ptractlc = tractive power of the appropriate cycle (kW)

c = GEM drive cycles where 1 = ARB transient cycle, 2 = 55 MPH cruise or 3 = 65 MPH
cruise cycles, shown in Table 2-11.

The recovered energy percentage was calculated by dividing the recovered energy by the
tractive energy, the final percent was then weighted by the appropriate distance weighting factor
and summed to end up with a final percent of energy recovered during regenerative braking for
each regulatory class based on the GEM duty cycles using Equation 2-9 the results may be found

Where,

kWhrec= recovery energy of the vehicle for cycle, c
kWhrec= tractive energy of the vehicle for cycle, c

c = GEM drive cycles where 1 = ARB transient cycle, 2 = 55 MPH cruise or 3 = 65 MPH
cruise cycles, shown in Table 2-11.

The percent regen was then multiplied against the energy per mile at the axle to end up with
energy gain due to regenerative braking per mile using Equation 2-10. The results are in Table

in Table 2-14.

Equation 2-9 Percent Regenerative Braking

2-15.

Equation 2-10 Energy Recovered from Regenerative Braking

kWhaxie

're3en * mi

Where,

%regen = Percent regenerative breaking

1regen

209

-------
axle

= weighted energy consumption per mile at the axle

The ZEV baseline per-mile energy consumed is described in Equation 2-11. However,
additional energies are required for both the HVAC unit as well as the conditioning of the
battery; therefore, in this case, the ZEV vehicle level energy consumption is calculated as shown

in Equation 2-12. The per mile PTO (~~^~) and per mile temperature related energy
consumption equations are described in Chapter 2.2.2.2.

Equation 2-11 ZEV Baseline Line Energy Consumption Per Mile

kWhbasUne

kWhaxle kWhregen kWh

PTO

mi mi mi

And,

Equation 2-12 ZEV Vehicle Level Energy Consumption Per Mile

kWhTot ^

veh mi mi

kWhbasline kWhjemp

Where,

kWflaxle

mi
kW

kW pq

mi
kW Temp

= weighted energy consumption at the axle
regen = regen energy consumption per mile
= PTO energy consumption per mile
= temperature related energy consumption per mile

2.7.2 Vehicle Miles Traveled

The annual miles driven for any particular vehicle changes over time, therefore we used a 10-
year average operating VMT in our payback analysis. The yearly operating VMT for each
vehicle (AORveh) for year i (Y^) is calculated using Equation 2-13.

Equation 2-13 VMT for Year i

AORve (Yi) = 0Rve topday(kaYi + kb)

Where,

t0pday = number of operational days, 250 days
ORve = 50th percentile range for a vehicle (mi/day)

Yt = Year at year i (where i = 0 to 9)

210

-------
ka = coefficient A
kb = coefficient B

Here, coefficients A and B of vocational vehicles and short-haul tractors are different from
long-haul tractors and for years 0 to 3 and years 4 to 9 according to Table 2-63.

Table 2-63 VMT Coefficients A and B

Year 0 to 3

Year 4 to 9

Vocational Vehicles
Short-Haul Tractors

0.0022

1.0015

-0.0588

1.1848

Long-Haul Tractors

0.0106

1.022

-0.0547

1.2181

The annual operational VMT (AORve ) is calculated to be the annual VMT averaged over a
10-year period (AORve ), as shown in Equation 2-14.

Equation 2-14 10 Year Averaged Annual VMT

AORve = ^ * two*. ) = 0Rve1t°'"",y » YikAYt + kB)

i=0 i=0

AORve = yearly operating VMT for each vehicle
t0pday = number of operational days, 250 days

ORVeh = 50th percentile range for a vehicle (mi/day)

Yt = Year at year i (where i = 0 to 9)
ka = coefficient A
kb = coefficient B

Likewise, the daily average operational range or VMT (DORveh) is calculated to be the daily
VMT averaged over a 10-year period. See Equation 2-15.

Equation 2-15 Average Daily operating VMT

AORygh

DORve = ——

lopday

AORve = 10-year average annual VMT for the vehicle (mi)
topday = number of operational days, 250 days

2.7.3 Power Take Off Loads

211

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In addition to baseload of moving a vehicle, heavy-duty vehicles also perform additional
functions such as lifting a garbage can or bucket. As explained in Chapter 2.2.2.1.4, PTO fuel
consumption is calculated using the percentage fuel consumption by auxiliary equipment type for
various HD applications from the California Department of Tax and Fee Administration.159 The
fuel consumption is converted into energy consumption in terms of kWh using the efficiency of
diesel HD vehicles and associated PTO components, the energy content of diesel fuel, and the
operational range and time of the PTO unit, as shown in Equation 2-16.

Equation 2-16 PTO Calculation

kWhPT0 AORve ( 1 \

— = (%PTO) - (FEice)

* V trans * Vhy

ve FEice \^size^op-d J

Where:

AORve = 10-year average annual VMT for the vehicle (mi)

FEice = GEM2 calculated fuel economy of the ICE vehicle (%), 35%

%PTO = percent fuel consumption from the PTO device

Rsize = 90th percentile daily sizing range (mi)

t0p-d = daily operating hours (hr)

V trans = Efficiency of the transmission (%), 95%

rjhyd = Efficiency of the hydraulic pump (%), 85%

2.7.4 ICE Technology

2.7.4.1 ICE Energy (Fuel) Consumption

In the case of ICE vehicles, fuel consumption was calculated by converting the GEM output
of grams of CO2 into gallons of diesel for each regulatory class using Equation 2-17. See Chapter
2.2.2.1.2 for the CO2 output of each regulatory class and Chapter 2.3.3 for fuel consumption
values.

Equation 2-17 ICE Vehicle Fuel Consumption

mpg,ce=y (9c° * —)

ICE Zj V10180 dc)

Where:

MPGice = mile per gallon of ICE vehicle

10,180 = conversion factor for grams of CO2 into gallon of diesel consumed

fc = the weighting factors for the respective GEM duty cycles, shown in Table 2-12.

dc = the distance in miles, shown in Table 2-11.

212

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2.7.4.2 Diesel Exhaust Fluid Consumption

DEF consumption (used in diesel vehicles) is a function of the DEF dosing rate where the
NOx reduction is estimated from the difference between estimated engine-out and tailpipe NOx
emissions, as described in Equation 2-18.

Equation 2-18 DEF Consumption

DEF = MPGice(-73.679x + 0.0149)

Where

MPGjce = mile per gallon of ICE vehicle

x = the DEF dosing rate (5.18%).

2.7.4.3 ICE Powertrain System Cost

The cost of a ZEV powertrain system is calculated to determine the cost difference from the
comparable ICE powertrain as described in Equation 2-19.

Equation 2-19 Cost of the ICE powertrain system

ClCEp-r = ^ Ci
i

Where,

Ct = Cost of ICE powertrain component i for the following components

i = Engine cost as determined based on engine power (kW) including projected costs to meet
the HD 2027 emission standards, gearbox, starter, torque converter clutch, final drive, and
generator.

2.7.5 BEV Technology

To better understand the technical feasibility and paybacks of BEV technologies, several
calculations were performed. For physical parameters, the energy consumption, weight, and
physical volume of battery packs for the 101 vehicle types as defined in the vehicle applications
are sized in the 2_BEV_Tech worksheet in HD TRUCS. Other attributes including motor power,
payload impact, and component costs associated with the BEVs are also incorporated into this
section.

2.7.5.1 Temperature Effects on BEV

BEVs also have added energy requirements for heating and cooling of the vehicles as well as
maintaining a constant temperature (conditioning) of the battery pack. The national average
heating and cooling requirements are determined from the MOVES HD vehicle VMT
distribution as a function of outside temperature, as well as the energy consumptions for HVAC
and battery conditioning, detailed description can be found in Chapter 2.2.2.2. From MOVES,
these values are broadly grouped into temperature ranges in Table 2-35 with average HVAC
(QbuT) in kW and battery conditioning (%BC) as function size of the battery.

213

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Table 2-64 Energy Consumption as a Function of Temperature Bands

Temperature Bins

% VMT

HVAC Power

Battery Conditioning

(°F)

Distribution

Consumption (kW)

(% of Battery)

<55

37%

5.06

1.9%

55-80

38%

>80

25%

3.32

4.2%

The power consumption for HVAC is rescaled for HD TRUCS using the surface area ratio for
each vehicle (SARve ) as in Equation 2-20.

Equation 2-20 SAR for Each Vehicle ID to SA of a Class 8 Bus

2*(L*H + L*W + W *H)[ve }

SARve ~ 2 *(L*H + L*W + W* H)[bus]

Where,

Lbus> Hbus> Wbus = length, height, and width of the bus, respectively

Lveh> Hve > Wve = length, height, and width of the vehicle, respectively

Table 2-65 shows the Lveh, Hveh, and Wveh different buses, ambulances, and for the
remainder of the vehicles.

Table 2-65 HD Vehicle Dimensions

Vehicle Type

W„„h (ft)

Hm.h (ft)

Kob (ft)

Class 2b-3

School Bus

7.5

6.3

Ambulance

Class 4-5

7.5

6.3

School Bus Ambulance

Class 6-7

School Bus

7.5

6.3

Transit Bus

Class 8 School Bus

7.5

6.3

Class 8 Coach Bus

7.5

6.3

All Other vehicles

5.2

6.35

9.7

The HVAC energy consumption for any one particular vehicle ID is then calculated using
Equation 2-21.

Equation 2-21 Energy Consumption from Heating or Cooling per mile

kWfliJUAr 1 / j, \

ZT; = n (SARveh*Qbus *topday)

mi ve resize

Where,

SAR = Surface area ratio of the vehicle compared to a Class 8 bus
QbusC =Power requirement to heat or cool the inside of a Class 8 bus

214

-------
t0pday = Daily operating time, 8 hrs
RSize = Vehicle 90th percentile VMT

Battery conditioning is expressed as a function of energy consumption, as shown in Equation
2-22

Equation 2-22 Battery Conditioning per mile

kWh

= %BC *

kWh

axle

veil

axle

= weighted energy consumption at the axle for the vehicle

%BC = percent battery conditioning, Table 2-64
2.7.5.2 BEVEnergy Consumption Per Mile

The energy consumption of a vehicle can be considered a function of the per mile energy
consumption, the daily VMT, and losses associated in converting the stored energy into
mechanical energy used to move the vehicle. In the case of BEVs, these losses include the
battery, DC/AC inverter, and e-motor efficiencies; therefore, the baseline energy consumption of
an electric heavy-duty vehicle are calculated using Equation 2-23:

Equation 2-23 BEV Baseline Energy Consumption

kWh

basline

kWh

basline

BEV

Vbev

And,

Equation 2-24 BEV Powertrain Efficiency

VBEV ~ Vbatt * VDCAC * Vmotor

Where,

kWhfoasnne

= ZEV baseline vehicle level energy consumption per mile

Vbev = efficiency of the battery BEV powertrain
TJbatt = efficiency of the battery
Vdcac = inverter efficiency
Vmotor = motor efficiency

The temperature related energy consumption consists of per mile energy consumption of the
HVAC and battery conditioning, here the same equation can be used for heating or cooling,
Equation 2-25

215

-------
mi

Where,

kw hvac

Equation 2-25 BEV Temperature Energy Consumption per Mile

— ^ * (kWhHVAC kWhBC\

BEV VbEV ^ mi mi ' ve

kWhTemp

kWh.Bc

= ZEV HAVC energy consumption per mile

•e

= ZEV battery conditioning energy consumption per mile

v eh

Vbev = efficiency of the battery BEV powertrain

2.7.5.3 BEV Battery Pack Sizing

Battery packs are sized to the energy requirement for the 101 vehicle types as defined in
Chapter 2.4.1.1 based on the vehicle class, duty cycle, and range requirements. The total energy
consumption per mile of BEVs (Equation 2-26) are converted balanced using the MOVES VMT
distribution in Table 2-64, baseline energy consumption, and temperature related energy
consumption.

kWh

Tot

Equation 2-26 Total Energy Consumption Per Mile For BEV

fkWhtemp kWhbaseline\ kWhbaseUne

= %VMT<55P = + + %VMT,

\ mi mi J

55 — 80F

Dm/ \ I III I III / mi

\ / BEV

BEV

(kWhfemp kWhbaseUne\

+ %VMT>80P ^ +

\ mi mi I

v ' BEV

Where,

%VMT<55p = percent of VMT at temperature < 55 °F
%VMT55_80 = percent of VMT at temperature 55-80 °F
%VMT>80 = percent of VMT at temperature > 80 °F

kWhfemv

———-= ZEV temperature related energy consumption per mile at temperature < 55 F

kWhfgmv ¦

———-= ZEV temperature related energy consumption per mile at temperature > 80 F

kWhfoasenne

= Baseline energy consumption per mile of the BEV

BEV

The pack capacity in terms of kWh is calculated using Equation 2-27.

Equation 2-27 Battery Pack Sizing

216

-------
, kWhTot
kWh 1

Lvack\BEV mi

( ) (1 + VDET) * Rsiz
\jInnn/

(—

BEV ^VDOD

Where

kWhTot

= vehicle level energy consumption for each BEV

BEV

Vdod = depth of discharge (80%)

Vdet = battery capacity deterioration over battery life (20%)

RSize = Vehicle 90th percentile VMT

Here, the axle energy required to move the vehicle on a per mile basis, as determined for each
of the 101 vehicle types as described in Chapters 2.2.2 and 2.4.1. Equation 2-26is adjusted to
account for the energy efficiency of the BEV's electrical system, a daily maximum level of
battery discharge, and the deterioration of battery capacity over time as shown in Equation 2-27.
The energy efficiency of a BEV, r/BEV, is described in Chapter 2.4.1. The maximum level of
discharge, r/D0D, is assumed to be 80%. We assumed the deterioration of the battery to be 20
percent over its life. These assumptions ensure that a BEV with a battery at the end of its life
would be able to operate on a 90th percentile VMT day, using only 80 percent of its battery
capacity. The pack size is calculated by the required range performance for the vehicle, RSize.
This range is assumed to be the 90th percentile VMT as described in Chapter 2.2.1.

HD TRUCS also evaluated the payload impact and width of the batteries in a BEV. The
physical pack weight and volume are calculated from the kWhpack and the projected pack level
specific energy (Wh/kg) and energy density (Wh/L) of batteries for MY 2027-2032 in Table
2-66. Furthermore, weight of the motor and gearbox are included to complete the BEV driveline
system.

Table 2-66 Pack Level Battery Properties

Pack Level Battery Properties

MY 2027

MY 2028

MY 2029

MY 2030

MY 2031

MY 2032

Specific Energy (Evack, Wh/kg)

199

203

208

213

218

223

Energy Density (ppack, Wh/L)

496

508

521

533

545

557

The weight of the pack (mpack) is calculated using Equation 2-28.

Equation 2-28 Weight of the Battery Pack

mpack\BEy \BEy * Epack

Where,

kWhpack \bev = battery pack energy for each
Epack = battery pack level specific energy

The weight of the BEV powertrain system is calculated using Equation 2-29.

Equation 2-29 Weight of BEV Powertrain

217

-------
m-BEV_PT |BEy ^Ylpack ^Ylmotor ^Ylgearbox

Where,

mpack = weight of the battery pack
mmotor = weight of the e-motor
™gearbox = weight of the gearbox

Using the weight of the BEV driveline and the weight of the ICE powertrain components as
calculated in Chapter 2.3.1, we calculated the payload impact (%PL) using Equation 2-30.

Equation 2-30 Payload Impact

TH-BEV PT TYllCE

%PL\veh = — * 100

mPL

Where,

mBEv_PT = weight of the BEV powertrain

rriicE = weight of the ICE powertrain system

mPL = weight of the payload for the associated GEM category

The volume of the pack (Vpack) is calculated using Equation 2-31.

Equation 2-31 Pack Volume

Vpack kWhpack * Ppack

Where,

kWhpack = energy of the battery pack
Ppack = Pa°k level energy density

Our assessment of the industry, as discussed in Chapter 1, shows that for existing HD BEVs,
the battery pack is likely to fit in a space that is defined in the length based on the vehicle's
wheelbase and in depth based on the depth of the ladder frame plus 10 percent. The volume of
the pack can, then, be converted to the width of the pack (Dwidth) for each of the vehicles using
Equation 2-32.

Equation 2-32 Battery Width

n Vpack

L-'width Tj . p.

Dwheelbase ^frame

Where,

218

-------
Dwheeibase = length of the wheelbase
Dframe = depth of the ladder frame *1.1

2.7.5.4 E-Motor Sizing

The e-motor in a BEV is used to convert electric energy into mechanical energy. To
determine the power requirement of the e-motor that would be required in the BEVs, the power
requirements for four performance metrics were calculated; these performance metrics are the
peak power requirement of the ARB transient cycle, 0-30 MPH vehicle acceleration times, 0-60
MPH vehicle acceleration times, and constant cruise at 6 percent grade as described in Chapter
2.4.1.2 and below.

Power requirements for the transient cycle were calculated using the road load power as
described in Equation 2-4; for motor sizing, the power requirement is determined to be the
absolute peak power requirement.

Power requirements to meet the 0-30 MPH and 0-60 MPH acceleration time targets were
calculated using Equation 2-33. The target times associated with each vehicle class are shown in
Table 2-39.

Equation 2-33 Power Required for Vehicle Acceleration

(vclass * (jnve + mrot) (mve * g * Crr

Pair * Vciass\ \ Vclass

aCC ~ V tacc I class V iooo 2 J J *1000

Where:

Pacc = Power required to accelerate to specific speed in kW

Vdass = Final velocity of the vehicle in the specific weight class in m/s

tacc\class = Time to accelerate to the final speed for the specific weight class in seconds

mveh = mass of the vehicle (kg)

g = gravitational constant of 32.2 m/s2

Crr = tire rolling resistance (kg/ton)

pair = density of air at a constant value of 1.17 (kg/m3)Power requirements to maintain a
constant cruise speed at 6 percent grade was calculated by applying a grade factor to the road
load power in Equation 2-4 and can be seen in Equation 2-34. The vehicle speed for each class of
vehicle was taken from ANL and can be seen in Table 2-39.17

Equation 2-34 Power Required for 6% Slope

, (mveh * g * cos tan-1 6 * Crr pair *CdA * v2class

*road\ve I 1000 2 ^veh * ^H-ve

. ^ _i ^ vciass * 0.44704

* sin tan 1 6 *

/ 1000

219

-------
Here:

mveh = mass of the vehicle (kg)
g = gravitational constant of 32.2 m/s2
6 = grade of 6%

Vdass = velocity by vehicle weight class as listed in Table 2-39.

Crr = tire rolling resistance in (kg/ton)

pair = density of air at a constant value of 1.17 (kg/m3)

ave = acceleration of the vehicle at each specific point of the duty cycle

The maximum value of the power required to perform the ARB transient cycle, accelerate 0-
30 MPH, 0-60 MPH, and of maintaining a specific speed on a 6 percent grade was divided by
the e-motor efficiency to calculate the power required of the electric motor for each vehicle in
Equation 2-35.

Equation 2-35 Power of Electric Motor

Pmotor\ve ~~

MAX(ProadARB

> Pacc0-30> Pac o-6o' ^road.6%)

'Imo tor

Where:

Pmotor = Power of electric motor in kW for each vehicle

Vmotor = Electric motor efficiency, as defined in Chapter 2.4.1.1.3

Pr0adARB = peak power requirement for ARB transient cycle

Pac o-so = Peak power requirement for acceleration from 0-30 MPH

Pac o-eo = Pea'< power requirement for acceleration from 0-60 MPH

Proad6% = Pea'< power requirement for maintaining a constant speed at 6 percent grade

2.7.5.5 BEV Powertrain System Cost

The cost of BEV powertrain systems is calculated to determine the cost difference from the
comparable ICE powertrain as described in Equation 2-36.

Equation 2-36 Cost of the BEV powertrain system

= 1

Cbevpt — ' Ci

Where,

Ct = Cost of BEV powertrain component i

220

-------
Here component i includes the battery pack (Cpack), e-motor (Cmotor), power electronics
(CpEied on-board charger (C0nCharger), gearbox (Cgearbox), differential (Cdiff) and accessories
(Cacc) costs. The individual component costs are described in Chapter 2.4.3. Furthermore, Cpack
and Cmotor are determined using Equation 2-37 and Equation 2-38. The cost of the battery pack
is determined from the pack size as sized in Chapter 2.4.1.1.3.

Equation 2-37 Cost of the Battery Pack

Cpack kWhpack * ( kW tl] kWhpack * ( IcW tl ^^battery / RPE J

\ ' IRA \ '

Where,

(few-) = effect've Per kilowatt-hr DMC of the battery. When this is multiplied by
RPE, the indirect costs are calculated based on the actual DMC as discussed in Chapter 2.4.3.1.

= Per kilowatt-hr DMC of the battery as shown in Table 2-43

IRAbattery = IRA total battery credits from Section 13502 as shown in Table 2-44
RPE = Retail Price Equivalent, 1.42

Likewise, the cost of the motor is determined using the size of the motor as sized in Chapter
2.7.5.4.

Equation 2-38 Cost of the E-Motor

r — Is]A/ * .

motor "-""motor fcyy

Where,

kWmotor = E-motor power

— = Per kilowatt cost of the electric motor.

For a breakdown of the e-drive component costs for all 101 vehicle types, see Table 2-48.

2.7.6 FCEV Technology

Several calculations were performed to understand the payback periods of FCEV
technologies. For physical parameters, fuel cell stack power output, the hydrogen consumption,
hydrogen fuel tank size, and physical volume of battery packs for the 101 vehicle types as
defined in the vehicle applications are sized in the 2_FCEV_Tech worksheet in HD TRUCS.
Other attributes including motor power, payload impact, and component costs associated with
the FCEVs are also incorporated into this section.

2.7.6.1 Fuel Cell Stack Power Requirement

221

-------
Power demand for the HD vehicles is calculated, using either the peak power at constant
cruise at 75 MPH or the 90th percentile power for the ARB transient cycle, using Equation 2-4
where the fuel cell stack power demand is determined to be the maximum of the two cycles
using Equation 2-39.

Equation 2-39 Power of Fuel Cell Stack

Ppc\veh = MAX(P^tBh,P75)

Where,

PARB1 = 90th percentile ARB transient cycle power

P75 = Peak power at 75 MPH cruise

2.7.6.2 E-Motor Sizing

The e-motors for FCEVs are sized the same way as the BEVs as described in Chapter 2.7.5.4.

2.7.6.3 FCEV Battery Pack Sizing

Battery packs are sized to provide 10 minutes of additional power requirements from the HD
vehicle that are not met by the fuel cell stack alone as shown in Equation 2-40.

Equation 2-40 FCEV Battery Pack Sizing

kWhpack | (^motor Ppc~) * tdischarge

Where,

Pmotor = Motor power
Ppc = Fuel Cell power

tdischarge = Battery discharge time, here it is assumed to be 10 minutes or 0.167 hour

2.7.6.4 Temperature Effects on FCEVs

While FCEVs can use waste heat from the FC stack like that of vehicles with internal
combustion engines, FCEVs have energy requirements for cooling of the vehicles as well as
maintaining a constant temperature (conditioning) of the battery pack. The considerations for
energy required to cool the interior cabin of the vehicle is similar to that of BEVs as described in
2.7.5.1, where the HVAC (Qj}™c) in kW and battery conditioning (%BC) are shown in Table
2-67. The per-mile energy consumption of HVAC and battery conditioning for FCEVs are
calculated using Equation 2-42.

Table 2-67 Energy Consumption as a Function of Temperature Bands

222

-------
Temperature Bins

% VMT

HVAC Power

Battery Conditioning

(°F)

Distribution

Consumption (kW)

(% of Battery)

<55

37%

1.9%

55-80

38%

>80

25%

3.32

4.2%

2.7.6.5 FCEV Energy Consumption Per Mile

Like ICE vehicles, the energy required of a FCEV is stored in the form of fuel which is
converted into mechanical energy by a powertrain system. In the case of a FCEV, the stored
energy is in the form of hydrogen fuel. Chapter 2.5.1.2 describes how the daily energy
consumption of a HD FCEV is considered, the consideration is similar ot that of BEV; briefly
these include the per-mile energy consumption, daily VMT, and losses associated with fuel cell
stack, DC/AC inverter, and e-motor efficiencies. The total energy consumption of a FCEV is
calculated using Equation 2-41:

Equation 2-41 FCEV Total Energy Consumption Per Mile

kWh

Tot

{kWhhasUne kWhj'emp\

fcev Vfcev ^ mi mi '

And,

Vfcev — Vfc * Vdcac * Vmotor

Where,

Vfcev = efficiency of the fuel cell powertrainr/FC = efficiency of the fuel cell stack
Vdcac = inverter efficiency
Vmotor = motor efficiency

kW milme = ^ase^ne Per m^e energy consumption at the axle, Equation 2-11 ZEV Baseline
Line Energy Consumption Per Mile

The temperature related energy consumption consists of per mile energy consumption of the
HVAC and battery conditioning, here the equation is be used for cooling only for HVAC and
heating and cooling for battery conditioning, see Chapters 2.7.5.1 and Equation 2-42.

Equation 2-42 FCEV Temperature Energy Consumption per Mile

1 (kWhHVAC kWhE

kWhfgjjip

Where,

kW HVAC

¦ *

fcev Vfcev

tkW hHVAC kWh.BC\
V mi mi A

kWhBc

v eh

= ZEV HVAC energy consumption per mile, for heating this value is 0
= ZEV battery conditioning energy consumption per mile

223

-------
iJfcev = efficiency of the battery FCEV powertrain

2.7.6.6 FCEV Hydrogen Storage and Use

The total energy consumption per mile of FCEVs (Equation 2-43) are converted balanced using
the MOVES VMT distribution in Table 2-64, baseline energy consumption, and temperature
related energy consumption.

Equation 2-43 Total Energy Consumption Per Mile For FCEV

kWh

Tot

n/im/ir kWhbaseline

— /oV M1 ;

FCEV ml

(kWhfZp kWh

+ %KM7W ^ +

baseline \

>80F i /

fcev \ mi mi I

tLhV \ /pcEV

mi
Where,

%VMT55_80 = percent of VMT at temperature 55-80 °F
%VMT>80F = percent of VMT at temperature > 80 °F

kWhfg-^L

ZEV temperature related energy consumption per mile at temperature > 80 °F

kWhbasenne

= Baseline energy consumption per mile of the BEV

BEV

The stored energy requirement (kWhs H2\veh), m the form of hydrogen fuel, is calculated

from the total energy consumption per mile of the FCEV using Equation 2-41 and the daily
sizing VMT (RSize), as shown in Equation 2-44.

Equation 2-44 Maximum Daily Energy Consumption of a FCEV

(kWhTot

kWhc Hi . —

lS_H2 \veh mi

FCEV'

Where

kWhTot

= total energy consumption per mile of FCEV

FCEV

RSize= Sizing range of the vehicle

The energy in kWh is converted into amount of hydrogen required, or stored hydrogen, using
the energy content for each kg of hydrogen using Equation 2-45.

Equation 2-45 Required Hydrogen Storage Weight

mSH21 = kWhs H2 (—yUh—"j ( ^

s.h2\veh V33.33 kWh) \riH2) \l - r]depletJ

Where,

224

-------
kWhs H2 = Daily maximum energy consumption of a FCEV
f]H2 =is the fraction of usable hydrogen (0.95)

Vdepie = oversizing to avoid complete depletion of usable hydrogen (0.10)

We differentiate the operating energy requirement (kWh0p_H2| ) from the sizing energy
requirement using daily operating VMT, as shown in Equation 2-46.

Equation 2-46 Daily Operational Energy Consumption of a FCEV

(kWhTot

kWhnr, H? = DORr

°P-H2\ve \ mi

Where,

FCEV'

DORve = daily average operational range or VMT, Equation 2-15

kWhTot

FCEV

= total energy consumption per mile for an FCEV, Equation 2-41

The energy in kWh is converted into amount of hydrogen required, or stored hydrogen, using
the energy content for each kg of hydrogen using Equation 2-47.

Equation 2-47 Required Hydrogen Weight for Operating the FCEV

= kWhOpJ<2 (33.33 kWh) (fa) (l-lwj

Where,

kWh0p H2 = Daily operating energy consumption of a FCEV
t]H2 = is the fraction of usable hydrogen (0.95)

Vdeplete = oversizing to avoid complete depletion of usable hydrogen (0.10)

The volume of the hydrogen fuel tank is calculated using the ideal gas law and the sizing
hydrogen weight (ms_H2), as shown in Equation 2-48 and Equation 2-49.

Equation 2-48 Volume of Hydrogen Fuel Tank

nRT

v=—

And

Equation 2-49 Number of Moles of Hydrogen

% H2

71 = ~rf—

MH2

Where,

225

-------
n = the number of moles of hydrogen per amount hydrogen

ms_H2 = weight of sizing hydrogen

R = Ideal gas constant, 8.31 J/mol*K

T = Temperature, 35 °C or 308 K

P = Tank pressure, 700 bar

MH2 = Molar mass of hydrogen, 2 g/mol

2.7.6.7 FCEV Powertrain System Cost

The cost of FCEV powertrain systems is calculated to determine the cost difference from the
comparable ICE powertrain as described in Equation 2-50.

Equation 2-50 Cost of the FCEV powertrain system

= 1

cfcevpt - / Cj

Where,

Cj = Cost of FCEV powertrain component j

Here component j includes the cost of fuel cell stack (CFC), hydrogen tank (CH2Tan X battery
pack (Cpack\ e-motor (Cmotor), power electronics (CPElec\ gearbox (Cgearbox), differential
(Cdiff) and accessories (Cacc). The individual component costs are described in Chapters 2.4.3
and 2.5.2. Most component costs are calculated the same way as BEVs, while Cpc and CH2Tank
are determined using Equation 2-51 and Equation 2-52.

Equation 2-51 Cost of the Fuel Cell Stack

Cpc — kWpc *¦

Where,

kWFC = Fuel cell stack power— = Per kilowatt cost of the fuel cell stack

The cost of the hydrogen tank is determined using the mass of the stored hydrogen (mH2),

Equation 2-52 Cost of Hydrogen Tank

CH2Tan ~ mS_H2 * kg ^

Where,

226

-------
ms_H2 = weight of stored hydrogen, kg- = Per kg hydrogen-stored cost of the hydrogen

k.g H 2

tank

2.7.7 Charging Infrastructure

For BEVs, we assign a per-vehicle cost associated with depot charging infrastructure to each
of the 101 vehicle types.

We start by estimating in Equation 2-53 how many hourslxxm it would take to charge a vehicle
sufficiently to cover its expected daily electricity consumption with each of four charging types:
Level 2-19.2 kW, DCFC-50 kW, DCFC-150 kW, DCFC-350 kW.

That is, for each charging type:

Equation 2-53 Hours to Recharge by Charging Type

tc = kWh-EV*~*Wc

Where,

tc = hours to recharge for each charging type

c = charging type

kWhBEV = daily electricity consumption (corresponding to 90th percentile daily VMT or
sizing VMT)

rjc = charging efficiency of charging type c (Table 2-68)lxxiv

kWc = power level for each charging type c

All vehicles are assumed to have a dwell time of at least 12 hours at the depot, as explained in
Chapter 2.6.4.1. Therefore, if tc is < 12 hours, we consider that charging type viable for depot
charging. For any of the three DC fast charging types, if tc < 6 hours, we additionally assume
two vehicles can share an EVSE port.

Table 2-68 Charging Efficiency160lxxv

2027

2028

2029

2030

2031

2032

Charging Efficiency

88.0%

88.25%

88.5%

88.75%

89.0%

89.25%

For each viable charging type, we then assign the appropriate per-vehicle EVSE cost from
Table 2-58. Finally, we select the minimum infrastructure cost among the charging types deemed

kxm Charging rate may vary based on the state of charge of the battery, e.g., by slowing down when the battery is
nearly full. We have made the simplifying assumption that the charging rate is uniform for this purpose.
kxlv We adjust the estimated electricity consumption upward to account for charging losses from the wall to the
battery. While these losses may vary by charging type and other factors, as a simplifying assumption, we assign the
same losses for all charging types.

kxv The charging efficiencies in the referenced study are presented as 88 percent in 2027 and 90 percent in 2035. We
use a linear interpolation for years 2027-2035.

227

-------
viable for the application in HD TRUCS and assign it to the vehicle category. The following
example illustrates this process.

For a vehicle that consumes 400 kWh of electricity per day (in 2027), the resulting charging
time estimates (rounded to the nearest hour) for each of the four charging types are shown in
Table 2-69.

Table 2-69 Example Charging Times (for 400 kWh of electricity demand)

Level 2 -19.2kW

DCFC—50 kW

DCFC—150 kW

DCFC—350 kW

24 hours

9 hours

3 hours

1 hour

In this case, we would consider all charging types except Level 2 to be viable choices for
depot charging.lxxvi Since the tc< 6 hours for DCFC—150 kW & DCFC—350 kW, we assume
two vehicles could share a plug for each of these types whereas each vehicle would need its own
plug for DCFC—50 kW.

Accordingly, the per-vehicle infrastructure costs for each of the viable charging options are
shown in Table 2-70.

Table 2-70 Example per-vehicle EVSE Costs in 2021$

Level 2 -19.2kW

DCFC—50 kW

DCFC—150 kW

DCFC—350 kW

$31,623

$49,543

$81,166

The lowest cost option is for a 50 kW DCFC port at about $32K so we would assign that
charging type and cost for the for the vehicle category in this example.

2.7.8 Payback

The payback period is calculated using the upfront price delta as well as the operating cost
difference between the comparable ICE vehicle and the ZEV, as shown in Equation 2-54.

Equation 2-54 Payback Period Calculation

_ (CzEVpr * RPE + PevSE) — ClCEpr * PP E
(,AFPdiesei — AFPzev fuet) + (MRice — MRzev)

Where,

RPE = Retail Price Equivalent, 1.42

Pevse = Cost of the EVSE unit, for BEV vehicles; in the case of FCEVs the unit cost is $0

kxvl Our infrastructure cost analysis is specific to depot charging, which as discussed in Chapter 2.6, is intended to
reflect charging at parking depots, warehouses, or other private locations where vehicles are parked off shift. We
further assume that all charging occurs during times the vehicle is not needed for operation (see discussion of dwell
time in Chapter 2.6.4.1). Therefore, we do not estimate any opportunity costs (e.g., costs from vehicle or employee
downtime) associated with time spent charging.

228

-------
AFPdiesei = Annual average diesel fuel consumption cost, as in Equation 2-55

AFPZev fuel = Annual average electricity or hydrogen consumption cost, as in Equation 2-56
and Equation 2-57

MR,ce = Maintenance and repair cost of an ICE vehicle, as in Equation 2-58

MRZEv = Maintenance and repair cost of a BEV, as in Equation 2-59, and of a FCEV as in
Equation 2-60

2.7.8.1 Operational Fuel Consumption Cost

Fuel costs for diesel, electricity, and hydrogen are calculated using the total energy per mile
consumption of the vehicle as described in Chapters 2.7.4.1, 2.4.4.2, and 2.7.6.4, respectively. In
the case of ICE vehicles, the GEM fuel economy (FE) values are reported in miles per gallon
instead of kWh per mile. For HD TRUCS computed per-mile energy consumption, the values are
reported in kWh/mi. Equation 2-55 describes the average annual diesel fuel consumption cost.

Equation 2-55 Annual Average Diesel Fuel Consumption Cost

(AORygh AORygh ^

AFPdiesel = —(1 + %PTO) * Pdiesel
\ r^iCE r^iCE J

Where,

AORve = Average annual operating VMT (Chapter 2.7.2)

Pdiesel = Price of diesel fuel, $/gal

%PT0 = Percent PTO use

Annual electricity consumption price for a BEV is calculated using the total per-mile energy
consumption, the average operating range and price of electricity as shown in Equation 2-56 and
described in Chapter 2.4.4.2

Equation 2-56 Annual Average Electricity Fuel Consumption Cost

kWhgEv

AFPeiec = AORve * ; * Pelec

Where,

AORveh = Average annual operating VMT (Chapter 2.7.2)
kW1^EV = the total per mile energy consumption for a BEV
Pelec = Price of electricity, $/kWh

The annual hydrogen consumption price on average during operation of the vehicle is
calculated using the operational energy consumption and the operating VMT:

Equation 2-57 Annual Average Hydrogen Consumption Cost

229

-------
AFPH2 = AORve F:EV)*PH2
\ mi /

Where,

AORve = Average annual operating VMT (Chapter 2.7.2)

kW^EV = the total per mile energy consumption for a FCEV, Chapter 2.7.6.4

2.7.8.2 Maintenance and Repair Cost

Maintenance and repair costs are calculated for ICE vehicles, BEVs, and FCEVs. The costs of
maintenance and repair for ICE vehicles is calculated annually using Equation 2-58:

Equation 2-58 Annual Average Maintenance and Repair of ICE Cost

MRice = ^+ h) * (kcYi + kd)

i=0

Where,

Yt = year i where i is between 0 and 9

ka_d = coefficients a-d

Here, coefficients a, b, c and d of vocational vehicles and short-haul tractors and for long-haul
tractors as described in Chapter 2.3.4.2 and shown in Table 2-71. These coefficients are derived
from equations found in the BEAN model.161 Note that coefficients a and b are the same
coefficients used for VMT change overtime (Y^)

Table 2-71 M&R Coefficients a-d

Year 0 to 3

Year 4 to 9

Year 0 to 9

Vocational Vehicles
Short-Haul Tractors

0.0022

1.0015

-0.0588

-0.0547

0.09

0.262

Long-Haul Tractors

0.0106

1.022

1.1848

1.2181

0.03

0.110

The maintenance and repair costs of BEVs and FCEVs are scaled from the maintenance and
repair costs of ICE vehicles for the same vehicle type as in Equation 2-59 and Equation 2-60.
Please see Chapters 2.4.4.1 and 2.5.3.2 for more details on the BEV and FCEV scaling factors.

Equation 2-59 Annual Average Maintenance and Repair of BEV Cost

MRBev = 0.71 * MRice

230

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Equation 2-60 Annual Average Maintenance and Repair of FCEV Cost
MR bev = 0.75 * MR ICE

2.7.9 Technology Adoption

In the heavy-duty sector, technology adoption rates often follow an S-shape. As discussed in
the preamble to the HD GHG Phase 2 final rule, the adoption rates are initially slow, followed by
a rapid adoption period, then leveling off as the market saturates.162 Studies have long used
payback period to inform new technology adoption rates.163 As a more recent example specific to
heavy-duty truck technologies, ACT Research translated payback years into technology adoption
rates.164

Equation 2-61 [Removed]

Table 2-72 [Removed]

In this proposal, we used a similar methodology to inform our ZEV technology adoption rates
in MY 2027 and MY 2032 in HD TRUCS (RTA)• The schedule, shown in Table 2-73, was
developed by EPA based on literature165'166'167'168'169'170'171'172 and EPA's engineering judgement.
There is limited existing data to support estimations of adoption rates of HD ZEV technologies.
The adoption rate method used for this proposal was developed after considering methods in the
literature to estimate adoption rates of ZEV technologies in the HD vehicle market. The methods
explored include the following: (1) the methods described in ACT Research's ChargeForward
report,173 (2) NREL's Transportation Technology Total Cost of Ownership (T3CO) tool,174 (3)
Oak Ridge National Laboratory's Market Acceptance of Advanced Automotive Technologies
(MA3T) model,175 (4) Pacific Northwest National Laboratory's Global Change Analysis Model
(GCAM),176 (5) ERM's market growth analysis done on behalf of EDF,177 (6) Energy

231

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Innovation's United States Energy Policy Simulator used in a January 2023 analysis by ICCT
and Energy Innovation,178 and (7) CALSTART's Drive to Zero Market Projection Model.179 Of
these methods explored, only ACT Research's work directly related payback period to adoption
rates. Based on our experience, payback is the most relevant metric to the HD vehicle industry,
and thus we relied on the ACT Research method to assess adoption rates, which we modified to
account for the effects of our proposed regulation.

The ZEV adoption schedule used to inform the proposed MY 2027 standards is similar to the
ACT Research schedule above, except that we have applied a faster adoption rate than the ACT
schedule in each payback period range that is greater than 4 years, due to the assumed impact of
this proposed regulation and the additional 80 percent constraint explained below. The MY 2032
adoption rate schedule applies higher rates of adoption in each payback period range than the
MY 2027 adoption rate schedule due to the fact that ZEV technology will be more mature; fleet
owners and drivers will have had more exposure to ZEV technology, which may alleviate
concerns of reliability and result in a lower impression of risk of these newer technologies; and
infrastructure to support ZEV technologies will have had more time to expand. More mature
technology and infrastructure and user familiarity and experiences typically translate to higher
rates of adoption,lxxv" as reflected in the higher adoption rates in MY 2032 compared to MY
2027 for payback period ranges greater than 1 year.

We applied an additional constraint within HD TRUCS that limited the maximum adoption
rate to 80 percent for any given vehicle type. This limit was developed after consideration of two
main factors. First, this 80 percent volume limit takes into account that we sized the batteries,
power electronics, e-motors, and infrastructure for each vehicle type based on the 90th percentile
of the average VMT. We utilize this technical assessment approach because we do not expect
heavy-duty OEMs to design ZEV models for the 100th percentile VMT daily use case for
vehicle applications, as this could significantly increase the EV powertrain size, weight, and
costs for a ZEV application for all users, when only a relatively small part of the market would
need such capabilities. Therefore, the ZEVs we analyzed and have used for the feasibility and
cost projections for this proposal are likely not appropriate for 100 percent of the vehicle
applications in the real-world. Our second consideration for including an 80 percent volume limit
for ZEVs is that we recognize there is a wide variety of real-world operation even for the same
type of vehicle. For example, some owners may not have the ability to install charging
infrastructure at their facility, or some vehicles may need to be operational 24 hours a day. Under
our proposed standards, ICE vehicles would continue to be available to address these specific
vehicle applications.

The schedule in MY 2027 was used to assign BEV adoption rates to each of the 101 HD
TRUCS vehicle types based on its payback period for MY 2027. For MY 2032, the adoption rate
schedule below was applied to both BEVs and select FCEVs.

Table 2-73 Adoption Rate Schedule in HD TRUCS

Payback (yr)

MY 2027

MY 2032

Adoption Rates

for BEVs

for BEVS and FCEVs

kxvn jhjg concept is consistent with theories developed by Everett Rogers. See https://sphweb.bnnic.bu. edn/otlt/niph -
modules/sb/behavioralchangetheories/behavioralchangetheories4.html for more information.

232

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<0

80%

0-1

55%

1-2

32%

45%

2-4

18%

35%

4-7

13%

25%

7-10

10%

20%

10-15

15%

>15

The individual vehicle adoption rate is then weighted using the 2019 sales volume and 2019
sales volume adjusted maximum as shown in Equation 2-62 and Equation 2-63.

Equation 2-62 Sales-Weighted Vehicle Adoption Rates

Rta\ve Rta\veh * $ve

Here,

RTA\ve = Vehicle-level adoption %

Sveh = Sales percent of the vehicle

In the case where the vehicle-level adoption rate is greater than the maximum adoption rate of
80%, the sales-weighted vehicle adoption rate becomes Equation 2-63.

Equation 2-63 Maximum Sales-Weighted Vehicle Adoption

Rta \ ve fmax * ^ve

fmax = Maximum vehicle-level adoption, 80%

The ZEV adoption values are aggregated into different levels for various calculations and
reporting. Generally, the aggregated technical adoption values are calculated using Equation
2-64.

Equation 2-64 Aggregated Technical Adoption

p, I _ (.^TA~)agg

"¦TAiagg ~

agg

Here,

R'ta \agg = The aggregated adjusted technical adoption rate where the aggregation can be on
any level

Sagg = Aggregated sales value that is aggregated to the same level as (R'ta)agg

2.8 HD TRUCS Analysis Results

HD TRUCS is a flexible tool that was used to analyze both the operational characteristics and
costs ZEV technologies) that we used to estimate heavy-duty ZEV technology feasibility and

233

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payback period. Then we translated the payback period, which is the number of years it would
take to offset any incremental cost increase of a ZEV over a comparable ICE vehicle, into
technology adoption of the BEV or FCEV.

2.8.1 Technology Feasibility

As discussed in Chapter 2.1, HD TRUCS evaluates the design features needed to meet the
power and energy demands of various HD vehicle types when using ZEV technologies. Since
BEV technology (and, likewise, FCEV technology) may be more suitable for some applications
compared to others, to assess the technical suitability of ZEVs for specific vehicle applications,
we created 101 representative vehicles in HD TRUCS that cover the full range of weight classes
within the scope of the proposed standards (Class 2b through 8 vocational vehicles and tractors.
The representative vehicles cover many aspects of work performed by the industry. This work
was translated into total energy and power demands per vehicle type based on everyday use of
HD vehicles, ranging from moving goods and people to mixing cement. We then identified the
technical properties required for a BEV or FCEV to meet the operational needs of a comparable
ICE HD vehicle.

Since batteries can add weight and volume to a vehicle, we evaluated battery mass and
physical volume required to package a battery pack. If the performance needs of a BEV resulted
in a battery that was too large or heavy, then we did not consider the BEV for that application in
our technology package because of the impact on payload and, thus, potential work
accomplished relative to a comparable ICE vehicle.

In the case of HD vehicles, battery mass may impact the overall payload available for use.
The payload mass impact is the difference in weight between an ICE powertrain and a BEV
powertrain. The mass of the ICE powertrain for each vehicle type can be found in Chapter 2.3.2.
The BEV battery weight is converted from the battery size (in terms of kWh) and the pack-level
specific energy of the battery. The battery specific energy values for MYs 2027-2032 can be
found in Chapter 2.4.2 and Table 2-41. The impact on payload from the battery is the delta
between battery weight and the weight of the ICE powertrain components divided by the payload
weight according to its respective GEM category, as described in Equation 2-28 and Equation
2-30. If a BEV could accommodate at least 70 percent of the payload of a comparable ICE
vehicle, then we deemed the BEV to have sufficient payload capacity. We chose a 30 percent
payload reduction as our cutoff point since most vehicles cube out (fill up with goods or
passengers before reaching maximum vehicle weight) before they gross out (reach maximum
vehicle weight before filling up with good or passengers) based on publicly available data that
was available during the time frame of this proposal.180

Like battery weight, the physical volume required to package a battery pack can also be
challenging to integrate onto a HD vehicle. The pack-level energy density Table 2-42) is used to
convert the battery size in terms of kWh into the volume of the battery. Here, the width of the
battery is calculated from a conversion of battery volume, using Equation 2-31 and Equation
2-32. The vehicle wheelbase length and the height of the vehicle's ladder frame are binned by
the vehicle class, as described in Chapter 2.3.1, and shown for each vehicle in Table 2-23. The
battery height is assumed to be able to extend slightly outside of the ladder frame, by 10 percent
of the ladder frame height. If the vehicle had a battery pack width of less than 8.5 feet, based on
the maximum width of a commercial vehicle, then we considered the vehicle application as a
BEV.181

234

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See Table 2-74 for a list of vehicles that we determined did not meet our payload impact and
battery size criteria for the MY 2027-2032 timeframe.

Table 2-74 Vehicles that Do Not Meet HD TRUCS BEV Payload Impact Criteria for MYs 2027-2032

Vehicle ID

Payload Impact (%)

2027

2028

2029

2030

2031

2032

17B Coach C18 R

40%

38%

37%

35%

33%

32%

18B Coach C18 MP

40%

38%

37%

35%

33%

32%

35T Ref C16-7 MP

31%

37T Ref C16-7 U

31%

38RV C18 R

46%

45%

43%

41%

40%

39%

39RV C16-7 R

72%

70%

68%

66%

64%

62%

40RV C14-5 R

84%

82%

80%

77%

74%

72%

41RV C12b-3 R

87%

85%

82%

79%

77%

75%

42RV C18 MP

46%

45%

43%

41%

40%

39%

43RV C16-7 MP

63%

61%

59%

57%

55%

54%

44RV C14-5 MP

73%

71%

69%

66%

64%

62%

45RV C12b-3 MP

75%

73%

71%

68%

66%

65%

78Tractor SC C18 MP

34%

33%

32%

30%

29%

79Tractor SC C18 R

50%

49%

47%

45%

44%

43%

85B Transit C18 MP

30%

86B Transit C16-7 MP

51%

50%

48%

46%

45%

44%

87B Transit C18 U

30%

88B Transit C16-7 U

51%

50%

48%

46%

45%

44%

Battery Width (ft)

2027

2028

2029

2030

2031

2032

78Tractor SC C18 MP

9.4

9.2

8.9

8.7

8.5

79Tractor SC C18 R

13.3

12.9

12.6

12.2

12.0

11.7

As described in Chapter 2.1, starting in MY 2030, we also considered FCEV technology for
select applications that travel longer distances and/or carry heavier loads. These vehicles, (shown
in Table 2-53 and Table 2-77) include two coach buses, two sleeper cab tractors, heavy haul
tractors, and three of the nine day cab tractors in HD TRUCS. In our analysis, these eight
vehicles were selected for fuel cell operation because they are generally longer route and/or
heavier haul applications.

2.8.2 Payback

After assessing the suitability of the technology and costs associated with ZEVs, a payback
calculation was performed on each of the 101 HD TRUCS vehicles for the BEV technology and
FCEV technology that we were considering for the technology packages for each use case for
each MY in the MY 2027-2032 timeframe. The payback period was calculated by determining
the number of years that it would take for the annual operational savings of a ZEV to offset the
incremental upfront purchase price of a BEV or FCEV (after accounting for the IRA section
13502 battery tax credit and IRA section 13403 vehicle tax credit as described in Chapters
2.4.3.1 and 2.4.3.5, respectively) and charging infrastructure costs (for BEVs) when compared to
purchasing a comparable ICE vehicle. The ICE vehicle and ZEV costs calculated include the
RPE multiplier of 1.42 to include both DMC and indirect costs, as discussed further in DRIA
Chapter 3. The operating costs include the diesel, hydrogen, or electricity costs, DEF costs, along

235

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with the maintenance and repair costs. The payback results are shown in Table 2-75 and Table
2-76 for BEVs for MY 2027 and MY 2032, and in Table 2-77 for FCEVs for MY 2032.

Table 2-75 Results of the BEV Payback Analysis for MY 2027 (2021$)

Vehicle ID

ICE PT

RPE
($/unit)

BEV PT

RPE
($/unit)

EVSE RPE
($/unit)

IRA
Vehicle
Tax Credit
($/unit)

ICE
Operating

($/year)

BEV
Operating

($/year)

BEV
Payback
(years)

01V Amb C14-5 MP

$39,923

$35,398

$10,541

$7,191

$4,625

02V Amb C12b-3 MP

$38,067

$37,276

$10,541

$10,475

$6,539

03V Amb C14-5 U

$39,923

$35,773

$10,541

$8,562

$5,177

04V Amb C12b-3 U

$38,067

$32,581

$10,541

$8,712

$5,183

05T Box C18 MP

$80,001

$82,998

$31,623

$2,997

$17,327

$10,789

06T Box C18 R

$80,001

$86,942

$31,623

$6,941

$16,429

$11,055

07T Box C16-7 MP

$43,108

$58,494

$10,541

$15,386

$9,531

$5,749

08T Box C16-7 R

$43,108

$63,378

$15,812

$20,269

$9,430

$5,949

09T Box C18 U

$68,494

$78,866

$31,623

$10,372

$19,165

$10,496

10T Box C16-7 U

$43,108

$59,809

$15,812

$16,700

$9,662

$5,431

1 IT Box C12b-3 U

$37,431

$41,619

$10,541

$4,188

$15,893

$9,241

12T Box C12b-3 R

$37,431

$47,254

$10,541

$7,500

$15,073

$9,679

13T Box C12b-3 MP

$37,431

$44,249

$10,541

$6,817

$15,378

$9,448

14T Box C14-5 U

$37,563

$40,493

$10,541

$2,930

$10,302

$5,995

15T Box C14-5 R

$37,563

$45,751

$10,541

$8,188

$9,771

$6,279

16T Box C14-5 MP

$37,563

$40,657

$10,541

$3,094

$9,969

$6,129

17B Coach C18 R

$60,918

$207,271

$81,166

$40,000

$40,087

$25,858

18B Coach C18 MP

$60,918

$207,271

$81,166

$40,000

$40,087

$25,858

19C Mix C18 MP

$68,494

$96,708

$31,623

$28,214

$29,566

$15,370

20T Dump C18 U

$80,001

$94,642

$31,623

$14,641

$12,475

$6,480

21T Dump C18 MP

$80,001

$98,962

$31,623

$18,961

$11,194

$6,633

22T Dump C16-7 MP

$42,863

$88,601

$31,623

$40,000

$14,214

$8,188

23 T Dump C18 U

$68,494

$94,642

$31,623

$26,148

$12,475

$6,480

24T Dump C16-7 U

$42,863

$81,840

$31,623

$38,977

$14,819

$7,955

25T Fire C18 MP

$80,001

$101,028

$31,623

$21,027

$11,656

$6,703

26T Fire C18 U

$68,494

$97,084

$31,623

$28,590

$13,048

$6,567

27T Flat C16-7 MP

$42,863

$58,363

$10,541

$15,501

$9,531

$5,749

28T Flat C16-7 R

$42,863

$63,246

$15,812

$20,384

$9,430

$5,949

29T Flat C16-7 U

$42,863

$54,231

$10,541

$11,369

$9,904

$5,576

30Tractor DC C18 MP

$81,893

$129,377

$31,623

$40,000

$19,892

$13,969

31 Tractor DC C16-7 MP

$63,999

$111,152

$31,623

$40,000

$22,293

$15,347

32Tractor DC C18 U

$79,719

$128,484

$31,623

$40,000

$19,892

$13,969

3 3 Tractor DC C16-7 U

$63,999

$111,152

$31,623

$40,000

$22,293

$15,347

34T Ref C18 MP

$64,444

$103,193

$31,623

$38,749

$17,899

$8,660

35T Ref C16-7 MP

$42,863

$107,758

$31,623

$40,000

$32,229

$16,305

36T Ref C18 U

$64,444

$103,193

$31,623

$38,749

$17,899

$8,660

37T Ref C16-7 U

$42,863

$107,758

$31,623

$40,000

$32,229

$16,305

38RV C18 R

$45,145

$169,897

$49,543

$40,000

$2,519

$1,561

141

39RV C16-7 R

$42,972

$175,286

$81,166

$40,000

$2,537

$1,589

183

40RV C14-5 R

$36,747

$116,909

$31,623

$40,000

$2,228

$1,418

41RV C12b-3 R

$38,562

$116,909

$31,623

$7,500

$2,228

$1,418

127

42RV C18 MP

$45,145

$169,897

$49,543

$40,000

$2,519

$1,561

141

43RV C16-7 MP

$42,972

$157,632

$49,543

$40,000

$2,564

$1,535

121

44RV C14-5 MP

$36,747

$105,640

$31,623

$40,000

$2,273

$1,384

45RV C12b-3 MP

$38,562

$105,640

$31,623

$7,500

$2,273

$1,384

103

236

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ICE PT

BEV PT

EVSE RPE
($/unit)

IRA
Vehicle
Tax Credit
($/unit)

ICE

BEV

Vehicle ID

RPI

($/unit)

RPE
($/unit)

Operating

($/year)

Operating

($/year)

Payback
(years)

46B School C18 MP

$45,145

$56,458

$10,541

$11,313

$11,982

$6,961

47B School C16-7 MP

$42,972

$52,081

$10,541

$9,108

$12,757

$7,259

48B School C14-5 MP

$36,747

$41,783

$10,541

$5,036

$10,176

$6,424

49B School C12b-3 MP

$38,562

$40,093

$10,541

$1,531

$10,176

$6,326

5OB School C18 U

$45,145

$54,767

$10,541

$9,623

$11,982

$6,854

5 IB School C16-7 U

$42,972

$52,081

$10,541

$9,108

$12,757

$7,259

52B School C14-5 U

$36,747

$39,530

$10,541

$2,783

$10,517

$6,287

53B School C12b-3 U

$38,562

$37,839

$10,541

$10,517

$6,189

54B Shuttle C14-5 MP

$36,747

$60,940

$15,812

$24,193

$24,956

$15,449

55B Shuttle C12b-3 MP

$38,562

$59,250

$15,812

$7,500

$24,956

$15,330

56B Shuttle C14-5 U

$36,747

$56,433

$10,541

$19,686

$25,791

$15,113

57B Shuttle C12b-3 U

$38,562

$54,743

$10,541

$7,500

$25,791

$14,994

58B Shuttle C16-7 MP

$42,972

$86,075

$31,623

$40,000

$28,159

$17,170

59B Shuttle C16-7 U

$42,802

$79,314

$31,623

$36,512

$29,261

$16,657

60S Plow C16-7 MP

$42,863

$44,089

$10,541

$1,227

$10,084

$5,993

61S Plow C18 MP

$80,001

$90,323

$31,623

$10,321

$12,381

$7,377

62S Plow C16-7 U

$42,863

$42,211

$10,541

$10,513

$5,839

63 S Plow C18 U

$68,440

$86,566

$31,623

$18,126

$13,797

$7,216

64V Step C16-7 MP

$42,769

$62,779

$15,812

$20,011

$14,567

$8,777

65V Step C14-5 MP

$36,747

$35,773

$10,541

$8,078

$4,987

66V Step C12b-3 MP

$38,067

$40,657

$10,541

$2,589

$12,580

$7,735

67V Step C16-7 U

$42,769

$58,084

$10,541

$15,316

$15,137

$8,511

68V Step C14-5 U

$36,747

$33,895

$10,541

$8,348

$4,878

69V Step C12b-3 U

$38,067

$38,215

$10,541

$147

$13,002

$7,566

70S Sweep C16-7 U

$42,691

$60,053

$15,812

$17,362

$13,551

$7,283

71T Tanker C18 R

$80,001

$94,079

$31,623

$14,078

$13,633

$8,818

72T Tanker C18 MP

$68,494

$90,510

$31,623

$22,016

$14,441

$8,634

73T Tanker C18 U

$68,664

$86,942

$31,623

$18,277

$16,092

$8,454

74T Tow C18 R

$80,001

$134,646

$49,543

$40,000

$17,015

$10,916

75T Tow C16-7 R

$42,863

$97,052

$31,623

$40,000

$14,027

$8,450

76T Tow C18 U

$68,664

$122,251

$31,623

$40,000

$20,084

$10,440

77T Tow C16-7 U

$42,691

$82,027

$31,623

$39,336

$14,793

$7,940

78Tractor SC C18 MP

$83,689

$315,460

$81,166

$40,000

$29,848

$22,148

79Tractor SC C18 R

$85,136

$419,133

$162,333

$40,000

$62,680

$46,450

80Tractor DC C18 HH

$85,936

$229,892

$81,166

$40,000

$21,587

$15,051

81 Tractor DC C17 R

$63,999

$148,526

$49,543

$40,000

$27,646

$18,997

82Tractor DC C18 R

$84,966

$275,807

$81,166

$40,000

$52,200

$36,524

83Tractor DC C17 U

$63,829

$148,526

$49,543

$40,000

$27,646

$18,997

84Tractor DC C18 U

$79,665

$273,663

$81,166

$40,000

$52,200

$36,524

85B Transit C18 MP

$60,918

$139,095

$49,543

$40,000

$39,390

$21,434

86B Transit C16-7 MP

$42,972

$143,734

$49,543

$40,000

$23,246

$12,623

87B Transit C18 U

$60,918

$139,095

$49,543

$40,000

$39,390

$21,434

88B Transit C16-7 U

$42,802

$143,734

$49,543

$40,000

$23,246

$12,623

89T Utility C18 MP

$79,947

$57,455

$10,541

$7,469

$4,523

90T Utility C18 R

$79,947

$59,146

$10,541

$7,052

$4,616

91T Utility C16-7 MP

$42,863

$61,368

$15,812

$18,506

$12,449

$7,258

92T Utility C16-7 R

$42,863

$65,875

$15,812

$23,013

$12,306

$7,500

93 T Utility C14-5 MP

$39,923

$44,976

$10,541

$5,053

$10,909

$6,517

94T Utility C12b-3 MP

$38,067

$33,144

$10,541

$4,992

$3,005

95T Utility C14-5 R

$39,923

$47,793

$10,541

$7,870

$10,671

$6,667

237

-------
Vehicle ID

ICE PT

RPE
($/unit)

BEV PT

RPE
($/unit)

EVSE RPE
($/unit)

IRA
Vehicle
Tax Credit
($/unit)

ICE
Operating

($/year)

BEV
Operating

($/year)

BEV
Payback
(years)

96T Utility C12b-3 R

$38,067

$47,793

$10,541

$7,500

$10,671

$6,667

97T Utility C18 U

$68,440

$55,953

$10,541

$8,324

$4,432

98T Utility C16-7 U

$42,863

$57,424

$10,541

$14,562

$12,979

$7,059

99T Utility C14-5 U

$39,923

$42,535

$10,541

$2,612

$11,311

$6,389

100T Utility C12b-3 U

$38,067

$31,829

$10,541

$5,176

$2,946

101 Tractor DC C18 U

$79,719

$122,474

$31,623

$40,000

$9,546

$6,663

Table 2-76 Results of the BEV Payback Analysis for MY 2032 (2021$)

Vehicle ID

ICE PT

RPE
($/unit)

BEV PT

RPE
($/unit)

EVSE RPE
($/unit)

IRA
Vehicle
Tax Credit
($/unit)

ICE
Operating

($/year)

BEV
Operating

($/year)

BEV
Payback
(years)

01V Amb C14-5 MP

$39,923

$26,321

$10,541

$7,284

$4,605

02V Amb C12b-3 MP

$38,067

$27,787

$10,541

$10,610

$6,512

03V Amb C14-5 U

$39,923

$26,615

$10,541

$8,680

$5,156

04V Amb C12b-3 U

$38,067

$24,269

$10,541

$8,833

$5,164

05T Box C18 MP

$80,001

$63,025

$31,623

$17,649

$10,715

06T Box C18 R

$80,001

$65,956

$31,623

$16,713

$10,976

07T Box C16-7 MP

$43,108

$44,166

$10,541

$1,058

$9,686

$5,719

08T Box C16-7 R

$43,108

$47,831

$15,812

$4,722

$9,581

$5,914

09T Box C18 U

$68,494

$59,800

$31,623

$19,564

$10,427

10T Box C16-7 U

$43,108

$45,047

$10,541

$1,937

$9,828

$5,405

1 IT Box C12b-3 U

$37,431

$31,131

$10,541

$16,113

$9,209

12T Box C12b-3 R

$37,431

$35,381

$10,541

$15,258

$9,639

13T Box C12b-3 MP

$37,431

$33,183

$10,541

$15,576

$9,412

14T Box C14-5 U

$37,563

$30,250

$10,541

$10,445

$5,975

15T Box C14-5 R

$37,563

$34,208

$10,541

$9,891

$6,253

16T Box C14-5 MP

$37,563

$30,425

$10,541

$10,097

$6,106

17B Coach C18 R

$60,918

$159,023

$81,166

$40,000

$40,798

$25,679

18B Coach C18 MP

$60,918

$159,023

$81,166

$40,000

$40,798

$25,679

19C Mix C18 MP

$68,494

$73,577

$31,623

$5,084

$30,259

$15,255

20T Dump C18 U

$80,001

$71,966

$31,623

$12,753

$6,436

21T Dump C18 MP

$80,001

$75,337

$31,623

$11,418

$6,586

22T Dump C16-7 MP

$42,863

$67,370

$31,623

$24,508

$14,465

$8,144

23 T Dump C18 U

$68,494

$71,966

$31,623

$3,472

$12,753

$6,436

24T Dump C16-7 U

$42,863

$62,094

$31,623

$19,232

$15,095

$7,915

25T Fire C18 MP

$80,001

$76,948

$31,623

$11,900

$6,655

26T Fire C18 U

$68,494

$73,871

$31,623

$5,377

$13,350

$6,522

27T Flat C16-7 MP

$42,863

$44,067

$10,541

$1,204

$9,686

$5,719

28T Flat C16-7 R

$42,863

$47,730

$15,812

$4,868

$9,581

$5,914

29T Flat C16-7 U

$42,863

$40,988

$10,541

$10,074

$5,549

30Tractor DC C18 MP

$81,893

$98,770

$31,623

$16,876

$20,221

$13,866

31 Tractor DC C16-7 MP

$63,999

$84,689

$31,623

$20,689

$22,631

$15,247

32Tractor DC C18 U

$79,719

$98,087

$31,623

$18,367

$20,221

$13,866

3 3 Tractor DC C16-7 U

$63,999

$84,689

$31,623

$20,689

$22,631

$15,247

34T Ref C18 MP

$64,444

$78,661

$31,623

$14,218

$18,331

$8,598

35T Ref C16-7 MP

$42,863

$82,173

$31,623

$39,311

$33,008

$16,180

36T Ref C18 U

$64,444

$78,661

$31,623

$14,218

$18,331

$8,598

238

-------

ICE PT

BEV PT

EVSE RPE
($/unit)

IRA
Vehicle
Tax Credit
($/unit)

ICE

BEV

Vehicle ID

RPI

($/unit)

RPE
($/unit)

Operating

($/year)

Operating

($/year)

Payback
(years)

37T Ref C16-7 U

$42,863

$82,173

$31,623

$39,311

$33,008

$16,180

38RV C18 R

$45,145

$130,150

$49,543

$40,000

$2,559

$1,552

39RV C16-7 R

$42,972

$134,285

$81,166

$40,000

$2,578

$1,580

133

40RV C14-5 R

$36,747

$89,344

$31,623

$40,000

$2,255

$1,412

41RV C12b-3 R

$38,562

$89,344

$31,623

$7,500

$2,255

$1,412

42RV C18 MP

$45,145

$130,150

$49,543

$40,000

$2,559

$1,552

43RV C16-7 MP

$42,972

$120,655

$49,543

$40,000

$2,606

$1,527

44RV C14-5 MP

$36,747

$80,550

$31,623

$40,000

$2,302

$1,379

45RV C12b-3 MP

$38,562

$80,550

$31,623

$7,500

$2,302

$1,379

46B School C18 MP

$45,145

$42,505

$10,541

$12,189

$6,924

47B School C16-7 MP

$42,972

$39,165

$10,541

$12,978

$7,222

48B School C14-5 MP

$36,747

$31,305

$10,541

$10,307

$6,397

49B School C12b-3 MP

$38,562

$29,986

$10,541

$10,307

$6,301

5OB School C18 U

$45,145

$41,186

$10,541

$12,189

$6,819

5 IB School C16-7 U

$42,972

$39,165

$10,541

$12,978

$7,222

52B School C14-5 U

$36,747

$29,546

$10,541

$10,662

$6,262

53B School C12b-3 U

$38,562

$28,227

$10,541

$10,662

$6,167

54B Shuttle C14-5 MP

$36,747

$46,107

$15,812

$9,361

$25,278

$15,389

55B Shuttle C12b-3 MP

$38,562

$44,788

$15,812

$6,226

$25,278

$15,272

56B Shuttle C14-5 U

$36,747

$42,590

$10,541

$5,843

$26,149

$15,059

57B Shuttle C12b-3 U

$38,562

$41,271

$10,541

$2,709

$26,149

$14,942

58B Shuttle C16-7 MP

$42,972

$65,547

$31,623

$22,574

$28,616

$17,077

59B Shuttle C16-7 U

$42,802

$60,124

$31,623

$17,322

$29,765

$16,573

60S Plow C16-7 MP

$42,863

$33,075

$10,541

$10,262

$5,958

61S Plow C18 MP

$80,001

$68,741

$31,623

$12,629

$7,324

62S Plow C16-7 U

$42,863

$31,609

$10,541

$10,709

$5,807

63 S Plow C18 U

$68,440

$65,810

$31,623

$14,105

$7,166

64V Step C16-7 MP

$42,769

$47,368

$15,812

$4,600

$14,803

$8,731

65V Step C14-5 MP

$36,747

$26,615

$10,541

$8,182

$4,968

66V Step C12b-3 MP

$38,067

$30,425

$10,541

$12,743

$7,706

67V Step C16-7 U

$42,769

$43,851

$10,541

$1,082

$15,397

$8,470

68V Step C14-5 U

$36,747

$25,150

$10,541

$8,464

$4,861

69V Step C12b-3 U

$38,067

$28,519

$10,541

$13,182

$7,540

70S Sweep C16-7 U

$42,691

$45,386

$15,812

$2,694

$13,810

$7,245

71T Tanker C18 R

$80,001

$71,525

$31,623

$13,888

$8,753

72T Tanker C18 MP

$68,494

$68,741

$31,623

$247

$14,730

$8,572

73T Tanker C18 U

$68,664

$66,102

$31,623

$16,451

$8,395

74T Tow C18 R

$80,001

$102,890

$49,543

$22,889

$17,333

$10,836

75T Tow C16-7 R

$42,863

$73,965

$31,623

$31,103

$14,271

$8,401

76T Tow C18 U

$68,664

$93,364

$31,623

$24,699

$20,532

$10,369

77T Tow C16-7 U

$42,691

$62,388

$31,623

$19,696

$15,070

$7,901

78Tractor SC C18 MP

$83,689

$242,341

$81,166

$40,000

$30,619

$21,882

79Tractor SC C18 R

$85,136

$322,512

$162,333

$40,000

$64,300

$45,893

80Tractor DC C18 HH

$85,936

$176,199

$81,166

$40,000

$22,239

$14,846

81 Tractor DC C17 R

$63,999

$113,562

$49,543

$40,000

$28,066

$18,874

82Tractor DC C18 R

$84,966

$211,699

$81,166

$40,000

$53,064

$36,257

83Tractor DC C17 U

$63,829

$113,562

$49,543

$40,000

$28,066

$18,874

84Tractor DC C18 U

$79,665

$210,062

$81,166

$40,000

$53,064

$36,257

85B Transit C18 MP

$60,918

$106,406

$49,543

$40,000

$40,210

$21,295

86B Transit C16-7 MP

$42,972

$109,956

$49,543

$40,000

$23,730

$12,542

239

-------

ICE PT

BEV PT

EVSE RPE
($/unit)

IRA
Vehicle
Tax Credit
($/unit)

ICE

BEV

Vehicle ID

RPE
($/unit)

Operating

($/year)

Operating

($/year)

Payback
(years)

87B Transit C18 U

$60,918

$106,406

$49,543

$40,000

$40,210

$21,295

88B Transit C16-7 U

$42,802

$109,956

$49,543

$40,000

$23,730

$12,542

89T Utility C18 MP

$79,947

$43,239

$10,541

$7,619

$4,489

90T Utility C18 R

$79,947

$44,558

$10,541

$7,184

$4,581

91T Utility C16-7 MP

$42,863

$46,265

$15,812

$3,403

$12,669

$7,217

92T Utility C16-7 R

$42,863

$49,929

$15,812

$7,067

$12,520

$7,455

93 T Utility C14-5 MP

$39,923

$33,650

$10,541

$11,064

$6,491

94T Utility C12b-3 MP

$38,067

$24,563

$10,541

$5,063

$2,993

95T Utility C14-5 R

$39,923

$35,994

$10,541

$10,816

$6,637

96T Utility C12b-3 R

$38,067

$35,994

$10,541

$10,816

$6,637

97T Utility C18 U

$68,440

$42,066

$10,541

$8,509

$4,401

98T Utility C16-7 U

$42,863

$43,334

$10,541

$472

$13,221

$7,023

99T Utility C14-5 U

$39,923

$31,744

$10,541

$11,483

$6,365

100T Utility C12b-3 U

$38,067

$23,537

$10,541

$5,255

$2,934

101 Tractor DC C18 U

$79,719

$93,396

$31,623

$13,677

$9,802

$6,583

Table 2-77 Results of the FCEV Payback Analysis for MY 2032 (2021$)

ICE PT

FCEV PT

IRA
Vehicle
Tax Credit
($/unit)

ICE

FCEV

Vehicle ID

Cost
($/unit)

Operating

($/year)

Operating

($/year)

Payback
(years)

17B Coach C18 R

$60,918

$102,491

$40,000

$40,798

$31,775

18B Coach C18 MP

$60,918

$102,491

$40,000

$40,798

$31,775

78Tractor SC C18 MP

$83,689

$128,727

$40,000

$30,619

$29,372

79Tractor SC C18 R

$85,136

$143,612

$40,000

$64,300

$61,604

80Tractor DC C18 HH

$85,936

$150,005

$40,000

$22,239

$20,515

81 Tractor DC C17 R

$63,999

$78,366

$14,366

$28,066

$23,324

82Tractor DC C18 R

$84,966

$119,967

$35,001

$53,064

$45,749

84Tractor DC C18 U

$63,829

$78,366

$14,537

$28,066

$23,324

Next, the payback periods were binned into seven categories and an adoption rate was applied
for each bin as shown in Table 2-73. This was performed for MYs 2027 and 2032 to account for
improvements in technology.

2.8.3 Technology Adoption

After the technology assessment, as described in Chapter 2.8.1, and payback analysis, as
described in Chapter 2.8.2, the ZEV adoption rates schedules described in Chapter 2.7.9 were
used to develop the ZEV adoption rates for MY 2027 and MY 2032.

2.8.3.1 ZEV Adoption Rates

Table 2-78 shows the MY 2027 and MY 2032 ZEV adoption rates that were calculated in HD
TRUCS and were built into our technology packages.

Table 2-78 HD TRUCS ZEV Adoption Rates by HD TRUCS Vehicle Type for the Proposal

240

-------
Vehicle ID

Sales %

MOVES
source
TypelD

MOVES
regClassID

Regulatory
Subcategory
Grouping3

MY
2027

MY
2032

01V Amb C14-5 MP

0.903%

LHD

18%

80%

02V Amb C12b-3 MP

0.618%

LHD

18%

55%

03V Amb C14-5 U

0.903%

LHD

32%

80%

04V Amb C12b-3 U

0.618%

LHD

32%

80%

05T Box C18 MP

0.319%

HHD

13%

35%

06T Box C18 R

0.216%

HHD

13%

35%

07T Box C16-7 MP

0.653%

MHD

18%

35%

08T Box C16-7 R

0.409%

MHD

13%

25%

09T Box C18 U

0.319%

HHD

18%

35%

10T Box C16-7 U

0.653%

MHD

18%

35%

1 IT Box C12b-3 U

5.650%

LHD

32%

55%

12T Box C12b-3 R

5.650%

LHD

18%

45%

13T Box C12b-3 MP

5.650%

LHD

32%

45%

14T Box C14-5 U

0.903%

LHD

18%

55%

15T Box C14-5 R

0.903%

LHD

18%

45%

16T Box C14-5 MP

0.903%

LHD

18%

55%

17B Coach C18 R

1.062%

HHD, Coach Bus

55%*

18B Coach C18 MP

1.062%

HHD, Coach Bus

55%*

19C Mix C18 MP

0.053%

HHD, Concrete Mixer

18%

35%

20T Dump C18 U

0.319%

HHD

13%

35%

21T Dump C18 MP

0.319%

HHD

13%

25%

22T Dump C16-7 MP

0.610%

MHD

13%

25%

23 T Dump C18 U

0.319%

HHD

13%

25%

24T Dump C16-7 U

0.610%

MHD

13%

25%

25T Fire C18 MP

0.025%

HHD

13%

25%

26T Fire C18 U

0.025%

HHD

13%

25%

27T Flat C16-7 MP

0.610%

MHD

18%

35%

28T Flat C16-7 R

0.610%

MHD

13%

25%

29T Flat C16-7 U

0.610%

MHD

18%

45%

30Tractor DC C18 MP

1.342%

13%

25%

31 Tractor DC C16-7 MP

0.640%

13%

25%

32Tractor DC C18 U

2.043%

13%

25%

3 3 Tractor DC C16-7 U

0.640%

13%

25%

34T Ref C18 MP

0.196%

HHD, Refuse hauler

18%

35%

35T Ref C16-7 MP

0.034%

MHD, Refuse hauler

45%

36T Ref C18 U

0.196%

HHD, Refuse hauler

18%

35%

37T Ref C16-7 U

0.034%

MHD, Refuse hauler

45%

38RV C18 R

0.350%

HHD

39RV C16-7 R

0.580%

MHD

40RV C14-5 R

1.118%

LHD

41RV C12b-3 R

1.096%

LHD

42RV C18 MP

0.350%

HHD

43RV C16-7 MP

0.580%

MHD

44RV C14-5 MP

1.118%

LHD

45RV C12b-3 MP

1.096%

LHD

46B School C18 MP

0.116%

HHD, School Bus

18%

45%

47B School C16-7 MP

1.480%

MHD, School Bus

32%

45%

48B School C14-5 MP

0.098%

LHD, School Bus

18%

45%

49B School C12b-3 MP

0.000%

LHD, School Bus

18%

55%

5OB School C18 U

0.116%

HHD, School Bus

18%

45%

5 IB School C16-7 U

1.480%

MHD, School Bus

32%

45%

241

-------
Vehicle ID

Sales %

MOVES
source
TypelD

MOVES
regClassID

Regulatory
Subcategory
Grouping3

MY
2027

MY
2032

52B School C14-5 U

0.098%

LHD, School Bus

18%

55%

53B School C12b-3 U

0.000%

LHD, School Bus

18%

55%

54B Shuttle C14-5 MP

0.148%

LHD

32%

45%

55B Shuttle C12b-3 MP

0.000%

LHD

18%

45%

56B Shuttle C14-5 U

0.712%

LHD

55%

57B Shuttle C12b-3 U

0.000%

LHD

32%

55%

58B Shuttle C16-7 MP

0.003%

MHD

18%

35%

59B Shuttle C16-7 U

0.048%

MHD

18%

35%

60S Plow C16-7 MP

0.610%

MHD

18%

55%

61S Plow C18 MP

0.319%

HHD

13%

35%

62S Plow C16-7 U

0.610%

MHD

18%

80%

63 S Plow C18 U

0.319%

HHD

13%

25%

64V Step C16-7 MP

0.015%

MHD

18%

35%

65V Step C14-5 MP

5.879%

LHD

18%

55%

66V Step C12b-3 MP

0.433%

LHD

18%

55%

67V Step C16-7 U

0.015%

MHD

32%

45%

68V Step C14-5 U

5.879%

LHD

18%

80%

69V Step C12b-3 U

0.433%

LHD

32%

55%

70S Sweep C16-7 U

0.610%

MHD

18%

35%

71T Tanker C18 R

0.319%

HHD

13%

25%

72T Tanker C18 MP

0.319%

HHD

13%

25%

73T Tanker C18 U

0.319%

HHD

13%

35%

74T Tow C18 R

0.319%

HHD

20%

75T Tow C16-7 R

0.610%

MHD

10%

25%

76T Tow C18 U

0.319%

HHD

13%

35%

77T Tow C16-7 U

0.610%

MHD

13%

25%

78Tractor SC C18 MP

3.590%

25%*

79Tractor SC C18 R

9.232%

25%*

80Tractor DC C18 HH

1.342%

Heavy Haul Tractor

15%*

81 Tractor DC C17 R

0.640%

55%*

82Tractor DC C18 R

1.342%

55%*

83Tractor DC C17 U

0.640%

25%

84Tractor DC C18 U

0.472%

55%*

85B Transit C18 MP

0.442%

HHD, Other Bus

35%

86B Transit C16-7 MP

0.003%

MHD, Other Bus

87B Transit C18 U

0.000%

HHD, Other Bus

35%

88B Transit C16-7 U

0.003%

MHD, Other Bus

89T Utility C18 MP

0.319%

HHD

80%

90T Utility C18 R

0.319%

HHD

80%

91T Utility C16-7 MP

0.610%

MHD

18%

35%

92T Utility C16-7 R

0.610%

MHD

18%

35%

93 T Utility C14-5 MP

0.903%

LHD

18%

55%

94T Utility C12b-3 MP

5.650%

LHD

18%

80%

95T Utility C14-5 R

0.797%

LHD

18%

45%

96T Utility C12b-3 R

0.433%

LHD

18%

35%

97T Utility C18 U

0.319%

HHD

80%

98T Utility C16-7 U

0.610%

MHD

32%

45%

99T Utility C14-5 U

0.903%

LHD

18%

55%

100T Utility C12b-3 U

5.650%

LHD

32%

80%

101 Tractor DC C18 U

0.007%

20%

242

-------
Vehicle ID

Sales %

MOVES
source
TypelD

MOVES
regClassID

Regulatory
Subcategory
Grouping3

MY
2027

MY
2032

*MY 2032 adoption rate is derived from FCEV adoption rate for these vehicles. All other vehicles are
derived from BEV adoption rates in HD TRUCS.

a LHD includes all Class 2b-5 vocational vehicle urban, multi-purpose, and regional subcategories. MHD
includes all Class 6-7 vocational vehicle urban, multi-purpose, and regional subcategories. HHD includes
all Class 8 vocational vehicle urban, multi-purpose, and regional subcategories. DC includes all Class 7-8
day cab tractor subcategories for all roof heights. SC includes all Class 8 sleeper cab subcategories for all
roof heights.

The total annual HD vehicle battery demand is determined from the annual pack demand for
BEV and FCEV. For each ZEV, the battery demand is calculated from the multiplication of the
battery size of the vehicle (as described in Chapter 2.7.5.3 for BEVs and Chapter 2.7.6.3 for
FCEVs) and the sales weighted vehicle adoption rates (Equation 2-62) for each vehicle type and
then summing the battery demand for all vehicle types (z) for each MY as shown in Equation
2-65,

Equation 2-65 Sales Weighted Battery Size for each MOVES SourceType ID and RegClass ID

. tATi kWflpack * ^TA Iveh

kWhM0VESID = :

TA I veh

Here,

kWhM0VESID = Sales weighted battery size for each MOVES SourceType ID and
RegClassID for each MY, Table 2-79

kWhpack= Battery pack size for BEV, Equation 2-27, or FCEV, Equation 2-40

R'ta I veh =sales weighted vehicle adoption rates, Equation 2-62

Equation 2-66 Annual Battery Demand for each MY in GWh

GWhMY = ^ SM0VEsjd * kWhM0VES ID

Smovesjd = vehicle sales for each MOVES Source TypelD and RegClassID vehicle for each
MY, Table 2-79

We estimate that the HD vehicle industry would produce 16.6 gigawatt-hours (GWh) of
batteries in MY 2027 for ZEVs and 36 GWh of batteries in MY 2032 for ZEVs. Table 2-79
shows the sales weighted battery pack size and vehicle sales for MY 2027 and MY 2032 BEV
and FCEV.

Table 2-79 Sales-Weighted Battery Pack Size and MOVES MY2027 and MY2032 Vehicle Sales

2027 Sales-

2027
MOVES

BEV
Vehicle
Sales

2032 Sales-

2032
MOVES

BEV
Vehicle
Sales

2032 Sales-

2032
MOVES
FCEV
Vehicle
Sales

MOVES
source
TypelD

MOVES
regClassID

weighted
Average
Battery Size
per BEV
(kWh)

weighted
Average
Battery Size
per FCEV
(kWh)

243

-------
41

463

1,374

5,229

202

5,767

200

6,449

193

191

313

309

144

226

916

224

1,440

217

215

349

346

605

126

605

1,147

167

302

165

661

168

8,625

166

11,805

118

550

116

1,716

109

108

413

592

409

1,156

459

380

35,774

129,779

103

80,409

193,034

239

6,304

280

8,585

148

896

223

12,476

210

27,060

319

131

315

288

140

227

309

224

434

366

122

2,595

121

5,126

1,590

156

1,233

155

2,949

1,006

186

532

325

1,049

1,255

4,574

996

3,382

604

6,404

497

9,372

11,031

500

2,881

506

5,812

4,262

13,984

2.9 Development of the Proposed CO2 Standards and Potential Alternative

Similar to the approach we used to support the feasibility of the HD GHG Phase 2 HD vehicle
CO2 emission standards, we developed technology packages that, on average, would meet each
of the proposed standards for each regulatory subcategory of vocational vehicles and tractors
after considering the various factors, including technology costs for manufacturers and costs to
purchasers. We applied these technology packages to nationwide production volumes to support
the proposed Phase 3 GHG vehicle standards. The technology packages utilize the averaging
portion of the longstanding ABT program, and we project manufacturers would produce a mix of
HD vehicles that utilize ICE-powered vehicle technologies and ZEV technologies with specific
adoption rates for each regulatory subcategory of vocational vehicles and tractors for each MY.
Note that we have analyzed a technology pathway to support the feasibility and appropriateness
of each proposed level of stringency for each proposed standard, but manufacturers would be
able to use a combination of HD engine or vehicle GHG-reducing technologies, including zero-
emission and ICE technologies, to meet the standards.

To support that the proposed emission standards are achievable through the technology
pathway projected in the technology packages, the proposed CO2 emission standards for each
regulatory subcategory were determined in two steps, giving consideration to costs, lead time,
and other factors, as described in the following two sections. First, we determined the technology

244

-------
packages that include ZEVs and ICE vehicles with GHG-reducing technologies for each of the
vocational vehicle and tractor subcategories, as described in Chapter 2.9.1. Then we determined
the numeric level of the proposed standards as described in Chapter 0 and shown in Chapter
2.9.3.

EPA also developed and considered an alternative level of proposed stringency for this
proposal which is described in Chapter 2.9.4.

2.9.1 Adoption Rates by Regulatory Subcategory

To calculate the ZEV adoption rates in the technology packages by regulatory subcategory for
each MY of this proposed rule, we first calculated sales-weighted average ZEV adoption rates
for each regulatory subcategory for MYs 2027 and 2032 from the information provided in Table
2-78 using Equation 2-64, as shown in Table 2-80.lxxvm The resulting projected ZEV adoption
rates and projected ICE vehicle adoption rates that achieve a level of CO2 emissions performance
equal to the existing MY 2027 emission standards were built into our technology packages.

Table 2-80 Projected ZEV Adoption Rates for MYs 2027 and 2032 Technology Packages

Regulatory Subcategory

MY 2027 ZEV Adoption Rates

MY 2032 ZEV Adoption Rates

LHD Vocational

22%

57%

MHD Vocational

19%

35%

HHD Vocational

16%

40%

MHD All Cab and HHD Day Cab Tractors

10%

34%

Sleeper Cab Tractors

25%

Heavy Haul Tractors

15%

Optional Custom Chassis: School Bus

30%

45%

Optional Custom Chassis: Other Bus

34%

Optional Custom Chassis: Coach Bus*

25%

Optional Custom Chassis: Refuse Hauler

15%

36%

Optional Custom Chassis: Concrete Mixer

18%

35%

* We are proposing to use the same adoption rates projected for sleeper cab tractors, which are also projected to be
FCEVs in MYs 2030-2032.

We phased in the adoption rates through MYs 2028-2031 by interpolating the MY 2027 and
MY 2032 adoption rates using the high-level adoption rates shown in Table 2-81. LHD
Vocational, MHD Vocational, HHD Vocational, and Heavy Haul Tractors followed the
Vocational phase-in from Table 2-81, MHD All Cab and HHD Day Cab Tractors followed the
Short Haul Tractors phase-in from Table 2-81, and Sleeper Cab Tractors followed the Long Haul
Tractors phase-in from Table 2-81. Among the Optional Custom Chassis subcategories, School
Bus, Other Bus, Refuse Hauler, and Concrete Mixer followed the Vocational phase-in.

Table 2-81 High-Level ZEV Adoption Rates in the Proposal

MY 2027

MY 2028

MY 2029

MY 2030

MY 2031

MY 2032 and Later

Vocational

20%

25%

30%

35%

40%

50%

Short Haul Tractors

10%

12%

15%

20%

30%

35%

Long Haul Tractors

10%

20%

25%

kxvm HD TRUCS vocational vehicle types that were generated using the Optional Chassis GEM cycles were
aggregated in two regulatory subcategories: (1) the relevant Optional Chassis regulatory subcategory and (2) the
corresponding vocational regulatory subcategory. The regulatory subcategories are shown in Table 2-78.

245

-------
An example calculation of this interpolation is shown in Equation 2-67 for LHD Vocational:
Equation 2-67 Example Calculation of LHD Vocational ZEV Adoption Rates for MYs 2028-2031

(Vocm - V0C2027)

LHDVm = LHD V2027 + (LHDV2032 - LHD V2027) * .

(VOC2032 " VOC2027)

Here,

LHDV = LHD Vocational ZEV adoption rate in the MY denoted by the subscript. Values for
MYs 2027 and 2032 can be found in Table 2-80.

m = The MY of interest (i.e., 2028, 2029, 2030, or 2031).

Voc = Vocational stringency in the MY denoted by the subscript. Values for MYs 2027-2032
can be found in Table 2-81.

Two exceptions to this calculation are for HHD Vocational and Heavy Haul Tractors. HHD
Vocational is slightly different due to the coach buses (Vehicle IDs 17B_Coach_C18_R and
18B_Coach_C18_MP), which are FCEVs in our technology package and phase in beginning in
MY 2030. These vehicles' adoption rates were phased in for MYs 2030 and 2031 by multiplying
the MY 2032 value by a ratio of the high-level adoption rates for either MY 2030 or MY 2031 to
MY 2032 (i.e., 35 percent /50 percent or 40 percent /50 percent, respectively). They were then
included in the calculation for HHD Vocational ZEV adoption rate by a sales-weighted average
using the Sales percent in Table 2-78 and Equation 2-64. Heavy Haul Tractors are also FCEVs in
our technology package and were calculated similarly to the coach buses, using the MY 2032
value for Vehicle ID 80Tractor_DC_C18_HH.

The resulting ZEV adoption rates in our technology packages for MYs 2027-2032 by
regulatory subcategory are shown in Table 2-82. The remaining portion of vehicles in each
technology package are projected to be ICE vehicles that achieve a level of CO2 emissions
performance equal to the existing MY 2027 emission standards.

246

-------
Table 2-82 Projected ZEV Adoption Rates for MYs 2027-2032 Technology Packages for the Proposal

Regulatory
Subcategory

MY 2027

ZEV
Adoption

MY 2028

ZEV
Adoption

MY 2029

ZEV
Adoption

MY 2030

ZEV
Adoption

MY 2031

ZEV
Adoption

MY 2032

ZEV
Adoption

LHD Vocational

22%

28%

34%

39%

45%

57%

MHD Vocational

19%

21%

24%

27%

30%

35%

HHD Vocational

16%

18%

19%

30%

33%

40%

MHD All Cab and
HHD Day Cab
Tractors

10%

12%

15%

20%

30%

34%

Sleeper Cab
Tractors

10%

20%

25%

Heavy Haul
Tractors

11%

12%

15%

Optional Custom
Chassis:
School Bus

30%

33%

35%

38%

40%

45%

Optional Custom
Chassis:
Other Bus

11%

17%

23%

34%

Optional Custom
Chassis:
Coach Bus*

10%

20%

25%

Optional Custom
Chassis:
Refuse Hauler

15%

19%

22%

26%

29%

36%

Optional Custom

Chassis:
Concrete Mixer

18%

21%

24%

27%

29%

35%

a We are proposing to use the same adoption rates projected for sleeper cab tractors, which are also projected to
be FCEVs in MYs 2030-2032

2.9.2 Calculation of the Proposed CO2 Standards

The heavy-duty vehicle CO2 emission standards are in grams per ton-mile, which represents
the grams of CO2 emitted to move one ton of payload a distance of one mile. The proposed
Phase 3 vehicle standards fall into two major categories: tractors and vocational vehicles and are
then further subdivided into regulatory subcategories standards. The following sections describe
how the proposed Phase 3 vehicle standards within each regulatory subcategory are calculated.

2.9.2.1 Calculation of the Proposed Standards for Tractors

The proposed CO2 emission standards for the tractor regulatory subcategories are calculated
by determining the CO2 emissions from a technology package that consists of both ICE-powered
vehicles and ZEVs. The projected fraction of ZEVs that emit zero grams CCh/ton-mile at the
tailpipe are shown in Table 2-82. The remaining fraction of vehicles in the technology package
are ICE-powered vehicles that include the technologies listed in the Preamble in Table II-1
(reflecting the GEM inputs for the individual technologies that make up the technology packages
that meet the existing MY 2027 CO2 tractor emission standards). Thus, in the technology
packages, the ICE-powered vehicles emit at the applicable existing MY 2027 CO2 emission
standards, as shown in Table 2-83. The proposed CO2 emission standards for each model year

247

-------
are calculated by multiplying the fraction of ICE-powered vehicles in each technology package
by the applicable existing MY 2027 CO2 emission standards. The proposed standards are
presented in Chapter 2.9.3.

Table 2-83 Existing MY 2027 Tractor CO2 Emission Standards (g/ton-mile)

Class 7

Class 8

Heavy Haul

(All Cab Styles)

(Day Cab)

(Sleeper Cab)

Low Roof

96.2

73.4

64.1

Mid Roof

103.4

78.0

69.6

48.3

High Roof

100.0

75.7

64.3

2.9.2.2 Calculation of the Proposed Standards for Vocational Vehicles

The proposed CO2 emission standards for the vocational vehicles regulatory subcategories are
calculated by determining the CO2 emissions from a technology package that consists of both
ICE-powered vehicles and ZEVs. The projected fraction of ZEVs that emit zero grams CCh/ton-
mile at the tailpipe are shown in Table 2-82. The remaining fraction of vehicles in the technology
package are ICE-powered vehicles that include the technologies listed in the Preamble in Table
II-2 (reflecting the GEM inputs for the individual technologies that make up the technology
packages that meets the existing MY 2027 CO2 vocational vehicles emission standards).

As discussed in the Preamble in Section II.C, vocational vehicle CO2 emission standards are
subdivided by weight class, Si-powered or Cl-powered vehicles, and by operation. There are a
total of 15 different vocational vehicle CO2 emission standards in the primary program for each
model year, in addition to the optional custom chassis standards. The existing MY 2027
vocational vehicle emission standards are shown in Table 2-84 (which, like tractors, are what the
ICE-powered vehicles emit at in the proposed technology packages). The HD GHG Phase 2
structure enables the technologies that perform best during urban driving or the technologies that
perform best at highway driving to each be properly recognized over the appropriate drive
cycles. The HD GHG Phase 2 structure was developed recognizing that there is not a single
package of engine, transmission, and driveline technologies that is suitable for all ICE-powered
vocational vehicle applications. In this proposal, we are continuing the current approach of
deeming tailpipe emissions of regulated GHG pollutants (including CO2) to be zero from electric
vehicles and hydrogen fuel cell vehicles.lxxix Therefore, the need to recognize the variety in
vocational vehicle CO2 emissions may no longer be necessary for ZEVs because ZEVs are
deemed to have zero CO2 emissions. Similarly, the existing SI and CI distinction within
vocational vehicle regulatory subcategory structure is not optimal for vocational ZEVs because
they cannot be technically described as either Si-powered or Cl-powered.

kxlx See proposed updates to 40 CFR 1037.150(f) for our proposed interim provision that CO2 emissions would be
deemed to be zero, with no C02-related testing, for BEVs, FCEVs, and vehicles powered by H2-ICE that solely use
hydrogen fuel. .

248

-------
Table 2-84 Existing MY 2027 Vocational Vehicle CO2 Emission Standards (g/ton-mile)

CI Light

Heavy

CI Medium

Heavy

CI Heavy
Heavy

SI Light
Heavy

SI Medium

Heavy

Urban

367

258

269

413

297

Multi-Purpose

330

235

230

372

268

Regional

291

218

189

319

247

Optional Custom
Chassis:

School Bus

271

Other Bus

286

Coach Bus

205

Refuse Hauler

298

Concrete Mixer

316

Motor Home

226

Mixed-Use Vehicle

316

Emergency Vehicle

319

Also discussed in the Preamble in Section II.C, the vehicle ABT program allows credits to
exchange with all vehicles within a weight class. ABT CO2 emission credits are determined
using the equation in 40 CFR 1037.705. The credits are calculated based on the difference
between the applicable standard for the vehicle and the vehicle's family emission limit
multiplied by the vehicle's regulatory payload and useful life. For example, as shown in Table
2-85, using the existing light heavy-duty vocational vehicle MY 2027 CO2 emission standards,
the amount of credit a ZEV would earn varies between 124 Mg and 177 Mg, depending on the
regulatory subcategory it would be certified to. We recognize that in many cases, it may not be
clear to the manufacturer whether to certify the vocational ZEV to a SI or CI regulatory
subcategory, i.e, for the manufacturer to know whether the ZEV was purchased in lieu of a
comparable Cl-powered or Si-powered vehicle. Furthermore, as just discussed, because ZEVs
have zero vehicle exhaust emissions, the programmatic basis for requiring the manufacturer to
differentiate the ZEVs by operation to appropriately account for the variety of driveline
configurations would not exist, though the amount of credit the ZEV would earn would depend
on the regulatory subcategory selected for certification. In short, we recognize the difficulties in,
and consequences of, determining which of the regulatory subcategories to which a ZEV should
be certified under the existing HD GHG Phase 2 emission standards' structure for vocational
vehicles. To address this concern, we are proposing a two-step approach. First, we propose to
revise the ABT credit calculation regulations; this change would begin in MY 2027. Second, we
derived the proposed MY 2027 and later standards accounting for the proposed changes to the
ABT credit calculations. Note that BEVs, FCEVs, and H2-ICE vehicles would still be able to be
certified to the vocational vehicle urban, multi-purpose, or regional standards or to the applicable
optional custom chassis standards.

Table 2-85 Example CO2 Emission Credit Calculations for Light Heavy-Duty (LHD) BEV/FCEVs by
Regulatory Subcategory based off the Existing MY 2027 standards

SI LHD
Urban

SI LHD
Multi-
purpose

SI LHD
Regional

CI LHD
Urban

CI LHD
Multi-
purpose

CI LHD
Regional

Existing MY 2027
Standard (gC02/ton-mile)

413

372

319

367

330

291

CO2 credit per BEV or
FCEV (Mg)

177

159

136

157

141

124

249

-------
EPA proposes to revise the definition of the variable "Std" in 40 CFR 1037.705 to establish a
common reference emission standard for vocational vehicles with tailpipe CO2 emissions deemed
to be zero (i.e., BEVs, FCEVs, and vehicles with engines fueled with pure hydrogen).lxxx
Beginning in MY 2027, manufacturers would use the applicable Compression-Ignition Multi-
purpose (CI MP) standard for their vehicle's corresponding weight class when calculating ABT
emission credits for vocational vehicles with tailpipe CO2 emissions deemed to be zero.lxxxi We
selected the CI MP standard because it is the regulatory subcategory with the highest production
volume in MY 2021. We also recognize a need to balance two different timing considerations
concerning the potential impacts of this proposed change. First, prior to the effective date of this
proposed change, there is a potential for manufacturers producing BEVs, FCEVs, and certain
H2-ICE vehicles to generate larger credits than they would after this change, depending on the
vocational vehicle subcategory to which a vehicle is certified. Second, we recognize that
manufacturers develop their emissions compliance plans several years in advance to manage
their R&D and manufacturing investments. After taking these into account, we propose that this
regulation revision become effective beginning in MY 2027 to provide manufacturers with
sufficient time to adjust their production plans, if necessary

Taking the proposed change to the ZEV ABT credit calculation into account, if we calculated
the proposed standards by multiplying the fraction of ICE-powered vehicles in the technology
package (by model year) by the applicable existing MY 2027 CO2 emission standards, like we
did for tractors, then this would lead to a scenario where it would take different levels of
adoption rates to meet the proposed standards in each regulatory subcategory than we included in
our assessment. Therefore, we used an alternate approach that maintains the same level of ZEV
adoption rates in each regulatory subcategory within a weight class, taking the proposed change
to the ZEV ABT credit calculation into account, The equation for calculating the proposed MY
2032 vocational vehicle standards is shown in Equation 2-68. This equation is used to calculate
the proposed standards for each vocational vehicle regulatory subcategory, using the existing
MY 2027 CI MP standard for each corresponding weight class (LH, MH, HH). Equation 2-69
through Equation 2-71 show how the proposed Equation 2-68 would be used for each regulatory
subcategory for an example model year (MY 2032). The existing MY 2027 standards can be
found in Table 2-84, and the projected ZEV adoption rates by model year are in Table 2-82. The
same equations are used for the proposed MY 2027 through 2031 standards but replacing the
MY 2032 Standards and ZEV adoption rates with values for the specific model year. The results
of the calculations for the MY 2027 through MY 2032 and later vocational vehicles are shown in
Table 2-86 through Table 2-91.

Equation 2-68 Proposed Vocational Vehicle Standard Calculation

MY 2032 Std RegSubcat — Existing 2027 Std RegSubcat (MY 2027 Existing CI MP StdRegsubcat * MY 2032 ZEV%)

Equation 2-69 Proposed Vocational Vehicle Standard Calculation Light Heavy-Duty Regulatory

Subcategories for MY 2032

kxx See proposed updates to 40 CFR 1037.150(f).

kxxl See 40 CFR 1037.105 for the compression-ignition multi-purpose C02 standards.

250

-------
MY 2032 StdRegsubcat = Existing 2027 StdRegsubcat - (330 g/mi * 57%)

Equation 2-70 Proposed Vocational Vehicle Standard Calculation Medium Heavy-Duty Regulatory

Subcategories for MY 2032

MY 2032 StdRegsubcat = Existing 2027 StdRegsubcat - (235 g/mi * 35%)

Equation 2-71 Proposed Vocational Vehicle Standard Calculation Heavy Heavy-Duty Regulatory

Subcategories for MY 2032

MY 2032 StdRegsubcat = Existing 2027 StdRegsubcat - (230 g/mi * 40%)

Table 2-86 Calculations of the Proposed MY 2027 CO2 Emission Standards for Vocational Vehicles

SI LHD Urban

SI LHD Multi-
purpose

SI LHD
Regional

CI LHD
Urban

CI LHD
Multi-
purpose

CI LHD
Regional

Existing MY 2027 Standard
(gCCh/ton-mile)

413

372

319

367

330

291

ZEV Adoption Rate in
Technology Package

22%

Proposed C02 Emission
Standard (gCC^/ton-mile)

340

299

246

294

257

218

SI Mill)

Urban

SI Mill)

Multi-Purpose

SI Mill)

Regional

CI Mill)

Urban

CI Mill)

Multi-
purpose

CIMHD
Regional

Existing MY 2027 Standard
(gCCh/ton-mile)

297

268

247

258

235

218

ZEV Adoption Rate in
Technology Package

19%

Proposed CO2 Emission
Standard (gCCh/ton-mile)

252

223

202

213

190

173

CI HHD
Urban

CI HHD
Multi-Purpose

CI HHD
Regional

Existing MY 2027 Standard
(gCCh/ton-mile)

269

230

189

ZEV Adoption Rate in
Technology Package

16%

Proposed CO2 Emission
Standard (gCCh/ton-mile)

232

193

152

251

-------
Table 2-87 Calculations of the Proposed MY 2028 CO2 Emission Standards for Vocational Vehicles

SILHD
Urban

SI LHD Multi-
purpose

SILHD
Regional

CI LHD
Urban

CI LHD
Multi-Purpose

CI LHD
Regional

Existing MY 2027 Standard
(gCCh/ton-mile)

413

372

319

367

330

291

ZEV Adoption Rate in
Technology Package

28%

Proposed CO2 Emission
Standard (gCC^/ton-mile)

321

280

227

275

238

199

SI Mill)

Urban

SIMHD
Multi-Purpose

SIMHD
Regional

CI Mill)

Urban

CI Mill)

Multi-Purpose

CI Mill)

Regional

Existing MY 2027 Standard
(gCCh/ton-mile)

297

268

247

258

235

218

ZEV Adoption Rate in
Technology Package

21%

Proposed CO2 Emission
Standard (gCCh/ton-mile)

248

219

198

209

186

169

CIHHD
Urban

CIHHD
Multi-Purpose

CIHHD
Regional

Existing MY 2027 Standard
(gCCh/ton-mile)

269

230

189

ZEV Adoption Rate in
Technology Package

18%

Proposed CO2 Emission
Standard (gCCh/ton-mile)

228

189

148

Table 2-88 Calculations of the Proposed MY 2029 CO2 Emission Standards for Vocational Vehicles

SILHD
Urban

SI LHD Multi-
Purpose

SILHD
Regional

CI LHD
Urban

CI LHD
Multi-Purpose

CI LHD
Regional

Existing MY 2027 Standard
(gCCh/ton-mile)

413

372

319

367

330

291

ZEV Adoption Rate in
Technology Package

34%

Proposed CO2 Emission
Standard (gCCh/ton-mile)

301

260

207

255

218

179

SI Mill)

Urban

SIMHD
Multi-Purpose

SIMHD
Regional

CI Mill)

Urban

CI Mill)

Multi-Purpose

CI Mill)

Regional

Existing MY 2027 Standard
(gCCh/ton-mile)

297

268

247

258

235

218

ZEV Adoption Rate in
Technology Package

24%

Proposed CO2 Emission
Standard (gCCh/ton-mile)

241

212

191

202

179

162

CIHHD
Urban

CIHHD
Multi-Purpose

CIHHD
Regional

Existing MY 2027 Standard
(gCCh/ton-mile)

269

230

189

ZEV Adoption Rate in
Technology Package

19%

Proposed CO2 Emission
Standard (gCCh/ton-mile)

225

186

145

252

-------
Table 2-89 Calculations of the Proposed MY 2030 CO2 Emission Standards for Vocational Vehicles

SILHD
Urban

SI LHD Multi-
purpose

SILHD
Regional

CI LHD
Urban

CI LHD Multi-
Purpose

CI LHD
Regional

Existing MY 2027 Standard
(gC02/ton-mile)

413

372

319

367

330

291

ZEV Adoption Rate in
Technology Package

39%

Proposed C02 Emission
Standard (gC02/ton-mile)

284

243

190

238

201

162

SI Mill)

Urban

SIMHD
Multi-Purpose

SIMHD
Regional

CI Mill)

Urban

CI MHD Multi-
Purpose

CI MHD
Regional

Existing MY 2027 Standard
(gC02/ton-mile)

297

268

247

258

235

218

ZEV Adoption Rate in
Technology Package

27%

Proposed C02 Emission
Standard (gC02/ton-mile)

234

205

184

195

172

155

CIHHD
Urban

CIHHD
Multi-Purpose

ci mil)

Regional

)r Vocational Vehicles

Existing MY 2027 Standard
(gC02/ton-mile)

269

230

189

ZEV Adoption Rate in
Technology Package

30%

Proposed C02 Emission
Standard (gC02/ton-mile)

200

161

120

Table 2-90 Calculations of the Proposed MY 2031 CO2 Emission Standards f(

SILHD
Urban

SI LHD Multi-
Purpose

SILHD
Regional

CI LHD
Urban

CI LHD Multi-
Purpose

CI LHD
Regional

Existing MY 2027 Standard
(gC02/ton-mile)

413

372

319

367

330

291

ZEV Adoption Rate in
Technology Package

45%

Proposed C02 Emission
Standard (gC02/ton-mile)

265

224

171

219

182

143

SI Mill)

Urban

SI Mill)

Multi-Purpose

SI Mill)

Regional

CI Mill)

Urban

CI MHD Multi-
Purpose

CI MHD
Regional

Existing MY 2027 Standard
(gC02/ton-mile)

297

268

247

258

235

218

ZEV Adoption Rate in
Technology Package

30%

Proposed C02 Emission
Standard (gC02/ton-mile)

227

198

177

188

165

148

ci hud

Urban

ci mil)

Multi-Purpose

CIHHD
Regional

Existing MY 2027 Standard
(gC02/ton-mile)

269

230

189

ZEV Adoption Rate in
Technology Package

33%

Proposed C02 Emission
Standard (gC02/ton-mile)

193

154

113

253

-------
Table 2-91 Calculations of the Proposed MY 2032 and Later CO2 Emission Standards for Vocational Vehicles

SILHD
Urban

SI LHD Multi-
purpose

SILHD
Regional

CI LHD
Urban

CI LHD Multi-
purpose

CI LHD
Regional

Existing MY 2027 Standard
(gC02/ton-mile)

413

372

319

367

330

291

ZEV Adoption Rate in
Technology Package

57%

Proposed C02 Emission
Standard (gC02/ton-mile)

225

184

131

179

142

103

SIMHD
Urban

SI Mill)

Multi-Purpose

SI Mill)

Regional

CI Mill)

Urban

CI MHD Multi-
purpose

CI MHD
Regional

Existing MY 2027 Standard
(gC02/ton-mile)

297

268

247

258

235

218

ZEV Adoption Rate in
Technology Package

35%

Proposed C02 Emission
Standard (gC02/ton-mile)

215

186

165

176

153

136

CIHHD
Urban

ci mil)

Multi-Purpose

CIHHD
Regional

Existing MY 2027 Standard
(gC02/ton-mile)

269

230

189

ZEV Adoption Rate in
Technology Package

40%

Proposed C02 Emission
Standard (gC02/ton-mile)

177

138

The HD GHG Phase 2 program includes optional custom chassis emission standards for eight
specific vehicle types. Those vehicle types may either meet the primary vocational vehicle
program standards or, at the vehicle manufacturer's option, they may comply with these optional
standards. The existing optional custom chassis standards are numerically less stringent than the
primary HD GHG Phase 2 vocational vehicle standards, but the ABT program is more restrictive
for vehicles certified to these optional standards. Banking and trading of credits is not permitted,
with the exception that small businesses may use traded credits to comply. Averaging is only
allowed within each subcategory for vehicles certified to these optional standards. If a
manufacturer wishes to generate tradeable credits from the production of these vehicles, they
may certify them to the primary vocational vehicle standards.

In this action, we are proposing to establish more stringent standards for several, but not all,
of these optional custom chassis subcategories. We are proposing revised MY 2027 emission
standards and new MY 2028 through MY 2032 and later emission standards for the school bus,
other bus, coach bus, refuse hauler, and concrete mixer optional custom chassis regulatory
subcategories. We are not proposing any changes to the existing ABT program restrictions for
the optional custom chassis regulatory subcategories. Because vehicles certified to the optional
custom chassis standards would continue to have restricted credit use and can only be used for
averaging within a specific custom chassis regulatory subcategory, we do not have the same
potential credit concern as we do for the primary vocational vehicle standards. Therefore, we
determined the proposed optional custom chassis emission standards using the same method as
the proposed tractor standards. The proposed CO2 emission standards were calculated by
multiplying the fraction of ICE-powered vehicles in the technology package (by model year) by

254

-------
the applicable existing MY 2027 CO2 emission standards, like we did for determining the
proposed tractor emission standards.

We are not proposing to set new standards for motor homes certified to the optional custom
chassis regulatory subcategory because of the projected impact of the weight of batteries in
BEVs in the MYs 2027-2032, as described in Chapter 2.8.1. Furthermore, we also are not
proposing new standards for emergency vehicles certified to the optional custom chassis
regulatory subcategory due to our assessment that these vehicles have unpredictable operational
requirements and may have limited access to recharging facilities while handling emergency
situations in the MYs 2027-2032 timeframe. Finally, we are not proposing new standards for
mixed-use vehicle optional custom chassis regulatory subcategory because these vehicles are
designed to work inherently in an off-road environment (such as hazardous material equipment
or off-road drill equipment) or be designed to operate at low speeds such that it is unsuitable for
normal highway operation and therefore may have limited access to on-site depot or public
charging facilities in the MYs 2027-2032 timeframe.lxxx" We do not have concerns that
manufacturers could inappropriately circumvent the proposed vocational vehicle standards or
proposed optional custom chassis standards because vocational vehicles are built to serve a
purpose. For example, a manufacturer cannot certify a box truck to the emergency vehicle
custom chassis standards.

2.9.3 Proposed CO2 Standards

The proposed standards are shown in Table 2-92 and Table 2-93 for vocational vehicles and
Table 2-94 and Table 2-95 for tractors.

The approach we used to select the proposed standards, described here and in the Preamble in
Section II, does not specifically include accounting for ZEV adoption rates that would result
from compliance with the California ACT program, given that EPA granted the ACT rule waiver
requested by California under CAA section 209(b) on March 30, 2023, which did not allow
enough time for EPA to consider a different approach for this proposal. The approach we used
developed ZEV technology adoption rates on a nationwide basis. With the recent granting of the
ACT waiver, we intend to consider how vehicles sold to meet the ACT requirement in California
and other states that may adopt it under CAA section 177 would impact or be accounted for in
the standard setting process approach described in the preamble in Section II. For example, we
may adjust our reference case to reflect the ZEV levels projected from ACT in California and
other states. We also may consider increasing the technology adoption rates in the technology
packages and correspondingly increase the stringency of the proposed Phase 3 emission
standards to account for the incremental difference in the projected ZEV adoption levels from the
proposed Phase 3 emission standards and the adoption levels projected from ACT in those states.

Table 2-92 Proposed MY 2027 through 2032+ Vocational Vehicle CO2 Emission Standards (g/ton-mile)

CI Light

Heavy

CI Medium

Heavy

CI Heavy
Heavy

SI Light Heavy

SI Medium

Heavy

MY 2027

Urban

294

213

232

340

252

Multi-Purpose

257

190

193

299

223

kxxn Mixecl_use vehicles must meet the criteria as described in 40 CFR 1037.105(h)(1), 1037.631(a)(1), and
1037.631(a)(2).

255

-------
Regional

218

173

152

246

202

MY 2028

Urban

275

209

228

321

248

Multi-Purpose

238

186

189

280

219

Regional

199

169

148

227

198

MY 2029

Urban

255

202

225

301

241

Multi-Purpose

218

179

186

260

212

Regional

179

162

145

207

191

MY 2030

Urban

238

195

200

284

234

Multi-Purpose

201

172

161

243

205

Regional

162

155

120

190

184

MY 2031

Urban

219

188

193

265

227

Multi-Purpose

182

165

154

224

198

Regional

143

148

113

171

177

MY 2032 and Later

Urban

179

176

177

225

215

Multi-Purpose

142

153

138

184

186

Regional

103

136

131

165

Table 2-93 Proposed MY 2027 through 2032+ Optional Custom Chassis Vocational Vehicle CO2 Emission

Standards (g/ton-mile)

MY 2027

MY 2028

MY 2029

MY 2030

MY 2031

MY 2032
and later

Optional Custom
Chassis: School
Bus

190

182

176

168

163

149

Optional Custom
Chassis: Other Bus

286

269

255

237

220

189

Optional Custom
Chassis: Coach Bus

205

185

164

154

Optional Custom
Chassis: Refuse
Hauler

253

241

232

221

212

191

Optional Custom
Chassis: Concrete
Mixer

259

250

240

231

224

205

Table 2-94 Proposed MY 2027 through MY 2032+ Tractor CO2 Emission Standards (g/ton-mile)

MY 2027

MY 2028

MY 2029

Class 7
All Cab
Styles

Class 8
Day Cab

Class 8
Sleeper
Cab

Class 7
All Cab
Styles

Class 8
Day Cab

Class 8
Sleeper
Cab

Class 7
All Cab
Styles

Class 8
Day Cab

Class 8
Sleeper
Cab

Low
Roof

86.6

66.1

64.1

84.7

64.6

64.1

81.8

62.4

64.1

256

-------
Mid
Roof

93.1

70.2

69.6

91.0

68.6

69.6

87.9

66.3

69.6

High
Roof

90.0

68.1

64.3

88.0

66.6

64.3

85.0

64.3

MY 2030

MY 2031

MY 2032 and Later

Class 7
All Cab
Styles

Class 8
Day Cab

Class 8
Sleeper
Cab

Class 7
All Cab
Styles

Class 8
Day Cab

Class 8
Sleeper
Cab

Class 7
All Cab
Styles

Class 8
Day Cab

Class 8
Sleeper
Cab

Low
Roof

77.0

58.7

57.7

67.3

51.4

51.3

63.5

48.4

48.1

Mid
Roof

82.7

62.4

62.6

72.4

54.6

55.7

68.2

51.5

52.2

High
Roof

80.0

60.6

57.9

70.0

53.0

51.4

66.0

50.0

48.2

Table 2-95 Proposed MY 2027 through MY 2032+ Heavy-Haul Tractor CO2 Emission Standards (g/ton-mile)

CO2 Emission Standards (g/ton-mile)

MY 2027

48.3

MY 2028

48.3

MY 2029

48.3

MY 2030

43.0

MY 2031

42.5

MY 2032 and Later

41.1

2.9.4 Summary of Costs to Meet the Proposed Emission Standards

In this subsection we show the cost of compliance for manufacturers for the proposed
standards as well as costs for purchasers.

The incremental cost of a heavy-duty ZEV is the marginal cost of ZEV powertrain
components compared to ICE powertrain components on a comparable ICE vehicle. This
includes the removal of the associated costs of ICE-specific components from the baseline
vehicle and the addition of the ZEV components and associated costs. Chapter 2.3.2 and 2.4.3
includes the ICE powertrain and BEV powertrain cost estimates for each of the 101 HD vehicle
types. Chapter 2.5.2 includes the FCEV powertrain cost projections for the coach buses, heavy-
haul tractors, sleeper cab tractors, and day cab tractors.

2.9.4.1 Manufacturer Costs

Table 2-96 and Table 2-97 show the ZEV technology costs for manufacturers, relative to the
reference case described in the Preamble in Section V.A.I, including the direct manufacturing
costs that reflect learning effects, the indirect costs, and the IRA section 13502 Advanced
Manufacturing Production Credit, on average aggregated by regulatory group for MYs 2027 and
2032, respectively.1™11 The incremental ZEV adoption rate reflects the difference between the

kxxm jncjirect costs are described in detail in DRIA Chapter III.B.2.

257

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ZEV adoption rates in the technology packages that support our proposed standards and the
reference case. As shown in Table 2-96 and Table 2-97, we project that some vocational vehicle
types will achieve technology cost parity between comparable ICE vehicles and ZEVs for
manufacturers by MY 2032. These vehicles in our analysis include school buses and single unit
trucks (which include vehicles such as delivery trucks). Our analysis is consistent with other
studies. For example, an EDF/Roush study found that by MY 2027, BEV transit buses, school
buses, delivery vans, and refuse haulers would each cost less upfront than a comparable ICE
vehicle.182 ICCT similarly found that "although zero-emission trucks are more expensive in the
near-term than their diesel equivalents, electric trucks will be less expensive than diesel in the
2025-2030 time frame, due to declining costs of batteries and electric motors as well as
increasing diesel truck costs due to emission standards compliance."183 These studies were
developed prior to passage of the IRA, and therefore we would expect the cost comparisons to be
even more favorable after considering the IRA provisions. For example, the Rocky Mountain
Institute found that because of the IRA, the TCO of electric trucks will be lower than the TCO of
comparable diesel trucks about five years faster than without the IRA. They expect cost parity as
soon as 2023 for urban and regional duty cycles that travel up to 250 miles and 2027 for long-
hauls that travel over 250 miles.184

Table 2-96 Manufacturer Costs to Meet the Proposed MY 2027 Standards Relative to the Reference Case

(2021$)

Incremental

Per-ZEV

Fleet-Average Per-

ZEV

Manufacturer

Vehicle

Regulatory Group

Adoption Rate
in Technology
Package

RPE on

Average

Manufacturer RPE

LHD Vocational

18%

$1,750

$323

MHD Vocational

15%

$15,816

$2,411

HHD Vocational

12%

-$505

-$62

Day Cab Tractors

$64,121

$5,187

Sleeper Cab Tractors

N/A

Table 2-97 Manufacturer Costs to Meet the Proposed MY 2032 Standards Relative to the Reference Case

(2021$)

Incremental

Per-ZEV

Fleet-Average Per-

ZEV Adoption

Manufacturer RPE

Vehicle Manufacturer

Regulatory Group

Rate in
Technology
Package

on Average

RPE

LHD Vocational

45%

-$9,515

-$4,326

MHD Vocational

24%

$1,358

$326

HHD Vocational

28%

$8,146

$2,300

Day Cab Tractors

30%

$26,364

$8,013

Sleeper Cab Tractors

21%

$54,712

$11,445

258

-------
2.9.4.2 Purchaser Costs

We also evaluated the costs of the proposed standards for purchasers on average by regulatory
group. Our assessment of the upfront purchaser costs include the incremental cost of a ZEV
relative to a comparable ICE vehicle after accounting for the two IRA tax credits (IRA section
13502, "Advanced Manufacturing Production Credit," and IRA section 13403, "Qualified
Commercial Clean Vehicles") and the associated EVSE costs, if applicable. We also assessed the
incremental annual operating savings of a ZEV relative to a comparable ICE vehicle. The
payback periods shown reflect the number of years it would take for the annual operating savings
to offset the increase in total upfront costs for the purchaser. The results of this analysis are
shown in Table 2-98 and Table 2-99.

Table 2-98 MY 2027 Purchaser Per-ZEV Upfront Costs, Operating Costs, and Payback Period (2021$)

Regulatory
Group

Adoption
Rate in
Technology
Package

Incremental

Per-ZEV
RPE Cost on
Average

EVSE Costs
Per-ZEV on
Average

Total
Incremental
Upfront Per-
ZEV Costs
on Average

Annual
Incremental
Operating
Costs on
Average

Payback
Period (year)
on Average

LHD Vocational

22%

-$1,733

$10,562

$8,828

-$4,474

MHD Vocational

19%

$482

$14,229

$14,711

-$5,194

HHD Vocational

16%

-$9,531

$19,756

$10,225

-$4,783

Day Cab Tractors

10%

$24,121

$37,682

$61,803

-$7,275

Sleeper Cab
Tractors

N/A

Table 2-99 MY 2032 Purchaser Per-ZEV Upfront Costs, Operating Costs, and Payback Period (2021$)

Regulatory
Group

Adoption
Rate in
Technology
Package

Incremental

Per-ZEV
RPE Cost on
Average

EVSE Costs
Per-ZEV on
Average

Total
Incremental
Upfront Per-
ZEV Costs
on Average

Annual
Incremental
Operating
Costs on
Average

Payback
Period (year)
on Average

LHD Vocational

57%

-$9,608

$10,552

$944

-$4,043

MHD Vocational

35%

-$2,907

$14,312

$11,405

-$5,397

HHD Vocational

40%

-$8,528

$17,233

$8,705

-$7,436

Day Cab Tractors

34%

$582

$16,753

$17,335

-$6,791

Sleeper Cab
Tractors

25%

$14,712

-$2,290

As shown in Table 2-99, under our proposal we estimate that the average upfront cost per
vehicle to purchase a new MY 2032 vocational ZEV and associated EVSE compared to a
comparable ICE vehicle (after accounting for two IRA tax credits, IRA section 13502,
"Advanced Manufacturing Production Credit," and IRA section 13403, "Qualified Commercial
Clean Vehicles"), would be offset by operational costs (i.e., savings that come from the lower
costs to operate, maintain, and repair ZEV technologies), such that we expect the upfront cost
increase would be recouped due to operating savings in one to three years, on average for
vocational vehicles. For a new MY 2032 day cab tractor ZEV and associated EVSE, under our
proposal we estimate the average incremental upfront cost per vehicle would be recovered in

259

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three years, on average. Similarly, for sleeper cab tractors, we estimate that the initial cost
increase would be recouped in seven years.

2.9.5 Potential Alternatives

EPA developed and considered an alternative level of proposed stringency based on a more
gradual phase-in of ZEV adoption rates for this proposal. A discussion about this alternative,
along with a more stringent set of emission standards that would be based on higher ZEV
adoption rates on a national level around the same levels as the adoption rates included in the
California ACT rule, is included in preamble Section II.H. The level of ZEV adoption rates for
MYs 2027 through 2032 and later under the proposed standards and the more gradual phase-in
alternative considered are shown in Table 2-100. The results of the analysis of this alternative are
included in Section IX of the preamble.

Table 2-100 Comparison of ZEV Technology Adoption Rates in the Technology Packages Considered for
Between the Proposed Standards and Alternative Considered

MY 2029

MY 2030

MY 2031

MY 2032 and

2027

2028

Later

Proposed

Vocational

20%

25%

30%

35%

40%

50%

Short Haul

10%

12%

15%

20%

30%

35%

Tractors

Long Haul

10%

20%

25%

Tractors

Alternative

Vocational

14%

20%

25%

30%

35%

40%

Short Haul

10%

15%

20%

25%

Tractors

Long Haul

10%

15%

20%

Tractors

Our calculation of the ZEV adoption rates by regulatory subcategory in the alternative mirrors
the method used to develop those in the proposal. However, ZEV adoption in the alternative for
MYs 2027 and 2032 were first adjusted from their levels in the proposal by a ratio of the MYs
2027 and 2032 levels shown in Table 2-100. For example, MY 2027 adoption rates in the
alternative for all regulatory subcategories using the Vocational phase-in were adjusted from
those of the proposal by a factor of 14%/20%. Likewise, MY 2032 adoption rates were
multiplied by 40%/50%. The resulting ZEV adoption rates for the alternative in MYs 2027-2032
by regulatory subcategory are shown in Table 2-101.

Table 2-101 Projected ZEV Adoption Rates for MYs 2027-2032 Technology Packages for the Alternative

Regulatory
Subcategory

MY 2027

ZEV
Adoption

MY 2028

ZEV
Adoption

MY 2029

ZEV
Adoption

MY 2030

ZEV
Adoption

MY 2031

ZEV
Adoption

MY 2032

ZEV
Adoption

LHD Vocational

15%

22%

28%

34%

40%

46%

MHD Vocational

13%

17%

20%

22%

25%

28%

HHD Vocational

11%

13%

15%

25%

28%

32%

260

-------
MHD All Cab and

HHD Day Cab

10%

15%

20%

25%

Tractors

Sleeper Cab
Tractors

10%

15%

20%

Heavy Haul Tractors

11%

12%

Optional Custom
Chassis:

21%

25%

28%

30%

33%

36%

School Bus

Optional Custom
Chassis:

12%

17%

22%

28%

Other Bus

Optional Custom
Chassis:

10%*

15%*

20%*

Coach Bus

Optional Custom
Chassis:

11%

15%

19%

22%

26%

29%

Refuse Hauler

Optional Custom
Chassis:

13%

16%

19%

22%

25%

28%

Concrete Mixer

* Similar to the projected adoption rates in Chapter 2.9.1, the adoption rates for coach buses are projected to be the
same as the adoption rates for sleeper cab tractors, which are also projected to be FCEVs in MYs 2030-2032.

Chapter 2 References

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2 California Air Resources Board. Advanced Clean Trucks Regulation: Public Hearing Notice and Related Material,
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https://cdn.stateofsustainablefleets.com/2022/state-of-sustainable-fleets-2022-miniguide-hfcev.pdf

10 U.S. Energy Information Administration. "Hydrogen explained: Use of hydrogen". Last updated January 20,
2022. Available online: https://www.eia.gov/energvexplained/hvdrogen/use-of-hvdrogen.php.

11 Toyota. "Toyota, Kenworth Prove Fuel Cell Electric Truck Capabilities with Successful Completion of Truck
Operations forZANZEFF Project". September 22, 2022. Available online: https://pressroom.tovota.com/tovota-
kenworth-prove-fuel-cell-electric-truck-capabilities-with-successful-completion-of-truck-operations-for-zanzeff-
project/.

12 Marcinkoski, Jason et. al. "DOE Advanced Truck Technologies: Subsection of the Electrified Powertrain
Roadmap—Technical Targets for Hydrogen-Fueled Long-Haul Tractor-Trailer Trucks. October 31, 2019. Available
online: https://www.hvdrogen.energy.gov/pdfs/19006 hydrogen class8 long haul truck targets.pdf.

13 U.S. Department of Energy. "DOE National Clean Hydrogen Strategy and Roadmap". Draft September 2022.
Available online: https://www.hvdrogen.energy.gov/pdfs/clean-hvdrogen-strategy-roadmap.pdf.

14 California Air Resources Board. Advanced Clean Trucks Regulation: Public Hearing Notice and Related Material,
"Appendix E: Zero Emission Truck Market Assessment". Posted October 22, 2019. Available online:
https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2019/act2019/appe.pdf.: California Air Resources Board,

Final Regulation Order - Advanced Clean Trucks Regulation. Filed March 15, 2021. Available online:
https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2019/act2019/fro2.pdf.

15 U.S. Environmental Protection Agency. "Greenhouse Gas Emissions Model (GEM) for Medium- and Heavy-Duty
Vehicle Compliance". Available online: https://www.epa.gov/regulations-emissions-vehicles-and-
engines/greenhouse-gas-emissions-model-gem-medium-and-heaw-dutv.

16 US EPA, 2019 Annual Production Volume Reports into Engine and Vehicle Compliance Information System.

17 Islam, Ehsan Sabri, Ram Vijayagopal, Aymeric Rousseau. "A Comprehensive Simulation Study to Evaluate
Future Vehicle Energy and Cost Reduction Potential", Report to the U.S. Department of Energy, Contract
ANL/ESD-22/6, October 2022. Available online: https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-
benefits/.

18 Islam, Ehsan Sabri, Ram Vijayagopal, Aymeric Rousseau. "A Comprehensive Simulation Study to Evaluate
Future Vehicle Energy and Cost Reduction Potential", Report to the U.S. Department of Energy, Contract
ANL/ESD-22/6, October 2022. See Medium- and heavy-duty vehicles (techno-economic analysis with BEAN).
Available online: https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/.

19 North American Council for Freight Efficiency (NACFE). "Electric Trucks Have Arrived: The Use Case for
Heavy-Duty Regional Haul Tractors—Run on Less Electric Report". May 5, 2022. Available online:
https://nacfe.org/wp-content/uploads/edd/2022/05/HD-Regional-Haul-Report-FINAL.pdf. NACFE used 250 days
per year for diesel and electric Class 8 tractors (regional haul) & vans and step vans.

20 NREL. Fleet DNA: Commercial Fleet Vehicle Operating Data. Available online
https://www.nrel.gov/transportation/fleettest-fleet-dna.html

21 Zhang, Chen, Karen Ficenec, Andrew Kotz, Kenneth Kelly, Darrell Sonntag, Carl Fulper, Jessica Brakora,

Tiffany Mo, and Sudheer Ballare. 2021. Heavy-Duty Vehicle Activity Updates for MOVES Using NREL Fleet
DNA and CE-CERT Data. Golden, CO: National Renewable Energy Laboratory. NREL/TP-5400-79509.

http s: //www. nrel. go v/doc s/fv 21 o sti/7 9509. pdf.

22 United States Census Bureau. 2002 Vehicle Inventory and Use Survey. Available online
https://www.census.gov/librarv/publications/2002/econ/census/vehicle-inventorv-and-use-survev.html.

23 CARB. Large Entity Reporting. Available online https: //ww2. arb. ca. go v/our-work/pro grams/advanced-clean-
trucks/large-entitv-reporting.

24 NREL and EPA. Heavy-Duty Vehicle Activity for EPA MOVES. Available online
https://data.nrel. gov/submissions/168, last accessed on October 15, 2022.

25 United States Census Bureau. 2002 Vehicle Inventory and Use Survey. Available online

https://www.census.gov/librarv/publications/2002/econ/census/vehicle-inventorv-and-use-survev.htmL last accessed
on October 15, 2022.

26 American Bus Association Foundation. "Motorcoach Census: A Study of the Size and Activity of the Motorcoach
Industry in the United States and Canada in 2017". June 5, 2019. Available online:
https://www.buses.org/assets/images/uploads/pdf/FINAL 2017 Census l.pdf.

262

-------
27 Federal Highway Administration. 2009 National Household Travel Survey: Average Annual Vehicle Miles of
Travel Per Vehicle (Best Estimate) By Vehicle Age and Type. Available online:
https://nhts.ornl.gov/tablesQ9/fatcat/2009/best VEHAGE VEHTYPE.html.

28 Coleman Company, Inc., and the Outdoor Foundation. "2016 American Camper Report". Available online:
https://outdoorindustrv.org/wp-content/uploads/2017/05/2016-Camper-Report FINAL.pdf.

29U.S. Department of Energy, Alternative Fuels Data Center. "Average Annual Vehicle Miles Traveled by Major
Vehicle Category". Last updated, February 2020; printed October 19, 2022. Available online:
https://afdc.energy.gov/data/widgets/10309.

30 California Air Resources Board. "Large Entity Fleet Reporting: Statewide Aggregated Data." Reported in 2021 on
2019 fleet data. Available online: https://ww2.arb.ca.gov/sites/default/files/2022-

02/Large Entity Reporting Aggregated Data ADA.pdf.

31 U.S. Environmental Protection Agency. Volume 81 FR 73478 (October 25, 2016).

32 U.S. Environmental Protection Agency. "Greenhouse Gas Emissions Model (GEM) v4.0 User Guide". July 2022.
Available online: https://nepis.epa.gov/Exe/ZvPDF.cgi?Dockev=Pl015AND.pdf.

33 U.S. Environmental Protection Agency. "Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium-
and Heavy-Duty Engines and Truck - Regulatory Impact Analysis." August 2016. EPA 420-R-16-900. See Chapters
4.4.1.9 and 4.4.1.10.

34 NREL, Characterization of PTO and Idle Behavior for Utility Vehicles, Sept 2017. Available online:
http s: //www. nrel. go v/doc s/fv 17 o sti/66747. pdf.

35 NREL, Fuel and Emissions Reduction in Electric Power Take-Off Equipped Utility Vehicles, June 2016.

Available online: https://www.nrel.gov/docs/fvl7osti/66737.pdf

36 See Cal. Code Regs. tit. 18, § 1432, "Other Nontaxable Uses of Diesel Fuel in a Motor Vehicle," available at
https://www.cdtfa.ca.gov/lawguides/vol3/dftr/dftr-regl432.html.

37 Ibid.

38 California Department of Tax and Fee Administration. Regulation 1432. Other Nontaxable Uses of Diesel Fuel in
a Motor Vehicle. Accessed October 2022. Available online: https://www.cdtfa.ca.gov/lawguides/vol3/dftr/dftr-
regl432.html#:~:text=in%20these%20percentages%3A-.Boom%20truck/block%20boom.l0%25.-

f 3)%20F or%20transactions.

39 U.S. Environmental Protection Agency. 87 FR at 17566. (March 28, 2022)

40 Islam, Ehsan Sabri, Ram Vijayagopal, Aymeric Rousseau. "A Comprehensive Simulation Study to Evaluate
Future Vehicle Energy and Cost Reduction Potential", Report to the U.S. Department of Energy, Contract
ANL/ESD-22/6. October 2022. See Full report. Available online: https://vms.taps.anl.gov/research-highlights/u-s-
doe-vto-hfto-r-d-benefits/.

41 Islam, Ehsan Sabri, Ram Vijayagopal, Aymeric Rousseau. "A Comprehensive Simulation Study to Evaluate
Future Vehicle Energy and Cost Reduction Potential", Report to the U.S. Department of Energy, Contract
ANL/ESD-22/6. October 2022. See Medium- and heavy-duty vehicles (techno-economic analysis with BEAN).
Available online: https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/.

42U.S. Environmental Protection Agency. "Greenhouse Gas Equivalencies Calculator—Calculations and
References. Accessed December 2022. Available online: https://www.epa.gov/energv/greenhouse-gases-
equivalencies-calculator-calculations-and-

references#:~:text=of%20diesel%20consumed.In%20the%20preamble%20to%20the%20ioint%20EPA%2FDepartm
ent%20of%20Transportation.emissions%20per%20gallon%20of%20diesel.

43 Hunter et. al. "Spatial and Temporal Analysis of the Total Cost of Ownership for Class 8 Tractors and Class 4
Parcel Delivery Trucks". National Renewable Energy Laboratory. September 2021. Available online:
http s: //www. nrel .go v/doc s/fv21osti/71796.pdf.

44Burnham, Andrew, David Gohlke, Luke Rush, Thomas Stephens, Yan Zhou, Mark A. Delucchi, Alicia Birky,
Chad Hunter, Zhenhong Lin, Shiqi Ou, Fei Xie, Camron Proctor, Steven Wiryadinata, Nawei Liu, and Madhur
Boloor. "Comprehensive Total Cost of Ownership Quantification for Vehicles with Different Size Classes and
Powertrains". April 2021. Accessible online: https://publications.anl.gov/anlpubs/2021/05/167399.pdf.

45 Ibid.

46 U.S. Energy Information Administration. Annual Energy Outlook 2022, Table 3: Energy Prices by Sector and
Source: Multiple Cases. Accessed December 2022. Available online:

https://www.eia. gov/outlooks/aeo/data/browser/#/?id=3-

263

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AE02022&cases=ref2022~highmacro~lowmacro~highprice~lowprice~highogs~lowogs~hirencst~lorencst~aeo201
9ref& sourcekev=0.

47 Basma, Hussein, Charbel Mansour, Marc Haddad, Maroun Nemer, Pascal Stabat. "Comprehensive energy
modeling methodology for battery electric buses". Energy: Volume 207, 15 September 2020, 118241. Available
online: https://www.sciencedirect.com/science/article/pii/S036054422Q313487.

48 Ibid.

49 Basma, Hussein, Charbel Mansour, Marc Haddad, Maroun Nemer, Pascal Stabat. "Comprehensive energy
modeling methodology for battery electric buses". Energy: Volume 207, 15 September 2020, 118241. Available
online: https://www.sciencedirect.com/science/article/pii/S036054422Q313487.

50 Brooker, Aaron, Alicia Birky, Evan Reznicek, Jeff Gonder, Chad Hunter, Jason Lustbader, Chen Zhang, Lauren
Sittler, Arthur Yip, Fan Yang, and Dong-Yeon Lee. "Vehicle Technologies and Hydrogen and Fuel Cell
Technologies Research and Development Programs Benefits Assessment Report for 2020." Golden, CO: National
Renewable Energy Laboratory. NREL/TP-5400-79617. 2021. Available online:

http s: //www, nrel .gov/docs/fv21osti/79617.pdf.

51 Nair et. al "Technical Review of: Medium and Heavy-Duty Electrification Costs for MY 2027-30—Final Report".
Environmental Defense Fund and Roush. February 2, 2022. Available online:
https://blogs.edf.org/climate41 l/files/2022/02/EDF-MDHD-Electrification-vl .6 20220209.pdf.

52 Ren, Dongshen. Hungjen Hsu, Ruihe Li, Xuning Feng, Dongxu Guo, Xuebing Han, Languang Lu, Xiangming He,
Shang Gao, Junxian Hou, Yan Li, Yongling Wang, Minggao Ouyang. "A comparative investigation of aging effects
on thermal runaway behavior of lithium-ion batteries." Available online:
https://www.sciencedirect.com/science/article/pii/S2590116819300347

53 Islam, Ehsan Sabri. Ram Vijayagopal, Ayman Moawad, Namdoo Kim, Benjamin Dupont, Daniela Nieto Prada,
Aymeric Rousseau, "A Detailed Vehicle Modeling & Simulation Study Quantifying Energy Consumption and Cost
Reduction of Advanced Vehicle Technologies Through 2050," Report to the US Department of Energy, Contract
ANL/ESD-21/10, October 2021. See previous reports and analysis: 2021. Available online:
https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/.

54 Islam, Ehsan Sabri, Ram Vijayagopal, Aymeric Rousseau. "A Comprehensive Simulation Study to Evaluate
Future Vehicle Energy and Cost Reduction Potential", Report to the U.S. Department of Energy, Contract
ANL/ESD-22/6, October 2022. Available online: https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-
benefits/.

55 55 Mitchell, George. Memorandum to docket EPA-HQ-OAR-2022-0985. " ACT Research Co. LLC. "Charging
Forward" 2020-2040 BEV & FCEV Forecast & Analysis, updated December 2021.

56 Islam, Ehsan Sabri. Ram Vijayagopal, Ayman Moawad, Namdoo Kim, Benjamin Dupont, Daniela Nieto Prada,
Aymeric Rousseau, "A Detailed Vehicle Modeling & Simulation Study Quantifying Energy Consumption and Cost
Reduction of Advanced Vehicle Technologies Through 2050," Report to the U.S. Department of Energy, Contract
ANL/ESD-21/10, October 2021. See previous reports and analysis: 2021. Available online:
https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/.

57 Islam, Ehsan Sabri. Ram Vijayagopal, Ayman Moawad, Namdoo Kim, Benjamin Dupont, Daniela Nieto Prada,
Aymeric Rousseau, "A Detailed Vehicle Modeling & Simulation Study Quantifying Energy Consumption and Cost
Reduction of Advanced Vehicle Technologies Through 2050," Report to the U.S. Department of Energy, Contract
ANL/ESD-21/10, October 2021. See previous reports and analysis: 2021. Available online:
https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/.

58 FEV. "FEV Update for EPA: Discussion Document". September 23, 2021.

59 Inflation Reduction Act of 2022, Pub. L. No. 117-169, 136 Stat. 1818 (2022), available at
httpsV/www.congress.gov/l 17/bills/hr5376/BILLS-l 17hr5376enr.pdf.

60 Federal Consortium for Advanced Batteries. "Executive Summary: National Blueprint for Lithium Batteries,
2021-2030". June 2021. Available online: https://www.energv.gov/sites/default/files/2021 -
06/FCAB%20National%20Blueprint%20Lithium%20Batteries%200621 O.pdf.

61 Bloomberg New Energy Finance (BNEF). "Battery Pack Prices Fall to an Average of $132/kWh, But Rising
Commodity Prices Start to Bite." November 30, 2021. Available online: https://about.bnef.com/blog/batterv-pack-
prices-fall-to-an-average-of-132-kwh-but-rising-commoditv-prices-start-to-bite/.

264

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62 Bloomberg New Energy Finance. "Lithium-ion Battery Pack Prices Rise for First Time to an Average of
$151/kWh". December 6, 2022. Available online: https://about.bnef.com/blog/lithium-ion-batterv-pack-prices-rise-
for-first-time-to-an-average-of-151 -kwh/.

63 Ricardo. "E-Truck Virtual Teardown Study: Final Report". The International Council on Clean Transportation.
June 11, 2021. Available online: https://theicct.org/wp-content/uploads/2022/01/Final-Report-eTruck-Virtual-

T eardown-Public-Version.pdf.

64 Ibid.

65 Wang, G. et. al. "White Paper: The Current and Future Performance and Costs of Battery Electric Trucks: A
Review of Key Studies and a Detailed Comparison of their Cost Modeling Scope and Coverage". National Center
for Sustainable Transportation. June 7, 2022. Available online: https://ncst.ucdavis.edu/research-product/current-
and-future-performance-and-costs-batterv-electric-trucks-review-kev.

66 YUNEV. "Industry Report: Commercial Vehicle Battery Cost Assessment—Strategic Sourcing Challenges for
North American Truck and Bus OEM and Tier 1 Suppliers". CALSTART. June 2021. Available online:
https://calstart.org/wp-content/uploads/2021/12/Commercial-Vehicle-Batterv-Costs-Industrv-Report-

Final 12.22.21.pdf.

67 Ibid.

68 Sharpe, Ben and Hussein Basma. "A meta-study of purchase costs for zero-emission trucks". The International
Council on Clean Transportation, Working Paper 2022-09 (February 2022). Available online:
https://theicct.org/publication/purchase-cost-ze-trucks-feb22/.

69 Islam, Ehsan Sabri. Ram Vijayagopal, Ayman Moawad, Namdoo Kim, Benjamin Dupont, Daniela Nieto Prada,
Aymeric Rousseau, "A Detailed Vehicle Modeling & Simulation Study Quantifying Energy Consumption and Cost
Reduction of Advanced Vehicle Technologies Through 2050," Report to the US Department of Energy, Contract
ANL/ESD-21/10, October 2021. See previous reports and analysis: 2021. Available online:
https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/.

70 Islam, Ehsan Sabri, Ram Vijayagopal, Aymeric Rousseau. "A Comprehensive Simulation Study to Evaluate
Future Vehicle Energy and Cost Reduction Potential", Report to the U.S. Department of Energy, Contract
ANL/ESD-22/6, October 2022. See Medium- and heavy-duty vehicles (techno-economic analysis with BEAN).
Available online: https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/.

71 Sharpe, Ben and Hussein Basma. "A meta-study of purchase costs for zero-emission trucks". The International
Council on Clean Transportation, Working Paper 2022-09 (February 2022). Available online:
https://theicct.org/publication/purchase-cost-ze-trucks-feb22/.

72 Inflation Reduction Act of 2022, Pub. L. No. 117-169, 136 Stat. 1818 (2022). Available online:
httpsV/www.congress.gov/l 17/bills/hr5376/BILLS-l 17hr5376enr.pdf.

73 Proterra. "First Proterra Powered commercial EV battery produced at new Powered 1 battery factory". January 12,
2023. Available online: https://www.proterra.com/press-release/first-batterv-at-poweredl-factorv/.

74 Sriram, Akash, Aditya Soni, and Hyunjoo Jin. "Tesla plans $3.6 bin Nevada expansion to make Semi truck,
battery cells." Reuters. January 25, 2023. Last accessed on March 31, 2023. Available online:
https://www.reuters.com/markets/deals/tesla-invest-over-36-bln-nevada-build-two-new-factories-2023-01-24/

75 Sion Power. "Cummins Invests in Sion Power to Develop Licerion® Lithium Metal Battery Technology for
Commercial Electric Vehicle Applications". November 30, 2021. Available online:

https://sionpower.com/2021/cummins-invests-in-sion-power-to-develop-licerion-lithium-metal-batterv-technologv-
for-commercial-electric-vehicle-applications/.

76 U.S. Department of Energy. "Bipartisan Infrastructure Law: Battery Materials Processing and Battery
Manufacturing & Recycling Funding Opportunity Announcement—Factsheets". October 19, 2022. Available
online: https://www.energy.gov/sites/default/files/2022-10/DOE%20BIL%20Batterv%2QFOA-
2678%20Selectee%20Fact%20Sheets%20-%201 2.pdf.

77 Slowik, Peter, et al. "Analyzing the Impact of the Inflation Reduction Act on Electric Vehicle Uptake in the
United States". The International Council on Clean Transportation and Energy Innovation: Policy and Technology.
January 31, 2023. Available online: https://energvinnovation.org/wp-content/uploads/2023/01/Analvzing-the-
Impact-of-the-Inflation-Reduction-Act-on-EV-Uptake-in-the-U.S..pdf

78 Kahn, Ari, et. al. "The Inflation Reduction Act Will Help Electrify Heavy-Duty Trucking". Rocky Mountain
Institute. August 25, 2022. Available online: https://rmi.org/inflation-reduction-act-will-help-electrifv-heaw-dutv-
trucking/.

265

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79 Sharpe, Ben and Hussein Basma. "A meta-study of purchase costs for zero-emission trucks". The International
Council on Clean Transportation, Working Paper 2022-09 (February 2022). Available online:
https://theicct.org/publication/purchase-cost-ze-trucks-feb22/. Costs are prior to integration markups.

80 Nair et. al "Technical Review of: Medium and Heavy-Duty Electrification Costs for MY 2027-30—Final Report".
Environmental Defense Fund and Roush. February 2, 2022. Available online:
https://blogs.edf.org/climate41 l/files/2022/02/EDF-MDHD-Electrification-vl .6 20220209.pdf.

81 Ibid.

82 Burke, Andrew, Marshall Miller, Anish Sinha, et. al. "Evaluation of the Economics of Battery-Electric and Fuel
Cell Trucks and Buses: Methods, Issues, and Results". August 1, 2022. Available online:
https://escholarship.org/uc/item/lg89p8dn.

83 Alternative Fuels Data Center. "How Do All-Electric Cars Work". U.S. Department of Energy. Available online:
https://afdc.energv.gov/vehicles/how-do-all-electric-cars-work.

84 Hunter et. al. "Spatial and Temporal Analysis of the Total Cost of Ownership for Class 8 Tractors and Class 4
Parcel Delivery Trucks". National Renewable Energy Laboratory. September 2021. Available online:

http s: //www. nrel .gov/docs/fv21osti/71796.pdf.

85 Nair et. al "Technical Review of: Medium and Heavy-Duty Electrification Costs for MY 2027-30—Final Report".
Environmental Defense Fund and Roush. February 2, 2022. Available online:
https://blogs.edf.org/climate41 l/files/2022/02/EDF-MDHD-Electrification-vl .6 20220209.pdf.

86 Islam, Ehsan Sabri, Ram Vijayagopal, Aymeric Rousseau. "A Comprehensive Simulation Study to Evaluate
Future Vehicle Energy and Cost Reduction Potential", Report to the U.S. Department of Energy, Contract
ANL/ESD-22/6, October 2022. See Medium- and heavy-duty vehicles (techno-economic analysis with BEAN).
Available online: https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/.

87 Ibid.

88 Nair et. al "Technical Review of: Medium and Heavy-Duty Electrification Costs for MY 2027-30—Final Report".
Environmental Defense Fund and Roush. February 2, 2022. Available online:
https://blogs.edf.org/climate41 l/files/2022/02/EDF-MDHD-Electrification-vl .6 20220209.pdf.

89 Islam, Ehsan Sabri, Ram Vijayagopal, Aymeric Rousseau. "A Comprehensive Simulation Study to Evaluate
Future Vehicle Energy and Cost Reduction Potential", Report to the U.S. Department of Energy, Contract
ANL/ESD-22/6, October 2022. See Medium- and heavy-duty vehicles (techno-economic analysis with BEAN).
Available online: https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/.

90 Inflation Reduction Act of 2022, Pub. L. No. 117-169, 136 Stat. 1818 (2022). Available online:
httpsV/www.congress.gov/l 17/bills/hr5376/BILLS-l 17hr5376enr.pdf.

91 Sharpe, B., Basma, H. "A meta-study of purchase costs for zero-emission trucks". International Council on Clean
Transportation. February 17, 2022. Available online: https://theicct.org/wp-content/uploads/2022/Q2/purchase-cost-
ze-trucks-feb22-l .pdf.

92 Burnham, A., Gohlke, D., Rush, L., Stephens, T., Zhou, Y., Delucchi, M. A., Birky, A., Hunter, C., Lin, Z., Ou,
S., Xie, F., Proctor, C., Wiryadinata, S., Liu, N, Boloor, M. "Comprehensive Total Cost of Ownership
Quantification for Vehicles with Different Size Classes and Powertrains". Argonne National Laboratory. April 1,
2021. Available at https://publications.anl.gov/anlpubs/2021/05/167399.pdf.

93 Burnham, A., Gohlke, D., Rush, L., Stephens, T., Zhou, Y., Delucchi, M. A., Birky, A., Hunter, C., Lin, Z., Ou,
S., Xie, F., Proctor, C., Wiryadinata, S., Liu, N, Boloor, M. "Comprehensive Total Cost of Ownership
Quantification for Vehicles with Different Size Classes and Powertrains". Argonne National Laboratory. April 1,
2021. Available online: https://publications.anl.gov/anlpubs/2021/05/167399.pdf.

94 Hunter, Chad, Michael Penev, Evan Reznicek, Jason Lustbader, Alicia Birkby, and Chen Zhang. "Spatial and
Temporal Analysis of the Total Cost of Ownership for Class 8 Tractors and Class 4 Parcel Delivery Trucks".
National Renewable Energy Lab. September 2021. Available online: https://www.nrel.gov/docs/fv21osti/71796.pdf.

95 Burke, Andrew, Marshall Miller, Anish Sinha, et. al. "Evaluation of the Economics of Battery-Electric and Fuel
Cell Trucks and Buses: Methods, Issues, and Results". August 1, 2022. Available online:
https://escholarship.org/uc/item/lg89p8dn.

96 Wang, G., Miller, M., and Fulton, L." Estimating Maintenance and Repair Costs for Battery Electric and Fuel Cell
Heavy Duty Trucks, 2022. Available online:

https://escholarship.org/content/qt36c08395/qt36c08395 noSplash 589098e470b036b3010eae00f3b7b618.pdf?t=r6
zwib.

266

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97 Type C BEV school bus battery warranty range five to fifteen years according to

https://www.nvapt.org/resources/Documents/WRI ESB-Buvers-Guide US-Market 2022.pdf. The Freightliner
electric walk-in van includes an eight year battery warranty according to https://www.electricwalkinvan.com/wp-
content/uploads/2022/05/MT50e-specifications-2022.pdf.

98 Basma, Hussein, Charbel Mansour, Marc Haddad, Maroun Nemer, Pascal Stabat. "Comprehensive energy
modeling methodology for battery electric buses". Energy: Volume 207, 15 September 2020, 118241. Available
online: https://www.sciencedirect.com/science/article/pii/S036054422Q313487.

99 ae, SH., Park, J.W., Lee, S.H. "Optimal SOC Reference Based Active Cell Balancing on a Common
Energy Bus of Battery" Available online: http://koreascience.or.kr/article/JAKQ201709641401357.pdf.

100 Azad, F.S., Ahasan Habib, A.K.M., Rahman, A., Ahmed I. "Active cell balancing of Li-Ion batteries using single
capacitor and single LC series resonant circuit." https://beei.Org/index.php/EEI/article/viewFile/l944/1491.

101 "How to Improve EV Battery Performance in Cold Weather" Accessed on March 31, 2023.
https://www.worktruckonline.com/10176367/how-to-improve-ev-batterv-performance-in-cold-weather.

102 U.S. Department of Energy, Energy Information Administration. Annual Energy Outlook 2022, Table 8:
Electricity Supply, Disposition, Prices, and Emissions. September 21, 2022. Available online:
https://www.eia. gov/outlooks/aeo/data/browser/#/?id=8-AE02022&cases=ref2022&sourcekev=0.

103 Islam, Ehsan Sabri, Ram Vijayagopal, Aymeric Rousseau. "A Comprehensive Simulation Study to Evaluate
Future Vehicle Energy and Cost Reduction Potential", Report to the U.S. Department of Energy, Contract
ANL/ESD-22.6, October 2022. See Full report. Available online: https://vms.taps.anl.gov/research-highlights/u-s-
doe-vto-hfto-r-d-benefits/.

104 Sakti, Apurba et. al. "What's cost got to do with it? An assessment of Tesla's Powerwall". MIT Energy Initiative.
June 12, 2015. Available online: https://energv.mit.edu/news/whats-cost-got-to-do-with-it/.

105 U.S. Department of Energy, US Drive. "Target Explanation Document: Onboard Hydrogen Storage for Light-
Duty Fuel Cell Vehicles". 2017. Available online:

https://www.energv.gov/sites/prod/files/2017/05/f34/fcto targets onboard hydro storage explanation.pdf.

106 Marcinkoski, Jason et. al. "DOE Advanced Truck Technologies: Subsection of the Electrified Powertrain
Roadmap—Technical Targets for Hydrogen-Fueled Long-Haul Tractor-Trailer Trucks. October 31, 2019. Available
online: https://www.hvdrogen.energv.gov/pdfs/19006 hydrogen class8 long haul truck targets.pdf.

107 Islam, Ehsan Sabri, Ram Vijayagopal, Aymeric Rousseau. "A Comprehensive Simulation Study to Evaluate
Future Vehicle Energy and Cost Reduction Potential", Report to the U.S. Department of Energy, Contract
ANL/ESD-22.6. October 2022. See Medium- and heavy-duty vehicles (assumptions). Available online:
https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/.

108 Sharpe, Ben and Hussein Basma. "A Meta-Study of Purchase Costs for Zero-Emission Trucks". The International
Council on Clean Transportation. February 2022. Available online: https://theicct.org/publication/purchase-cost-ze-
trucks-feb22/.

109 Inflation Reduction Act of 2022, Pub. L. No. 117-169, 136 Stat. 1818 (2022). Available online:
https://www.c0ngress.g0v/l 17/bills/hr5376/BILLS-l 17hr5376enr.pdf.

110 Marcinkoski, Jason et. al. "DOE Advanced Truck Technologies: Subsection of the Electrified Powertrain
Roadmap—Technical Targets for Hydrogen-Fueled Long-Haul Tractor-Trailer Trucks. October 31, 2019. Available
online: https://www.hvdrogen.energv.gov/pdfs/19006 hydrogen class8 long haul truck targets.pdf.

111 Deloitte China. "Fueling the Future of Mobility: Hydrogen and fuel cell solutions for transportation, Volume 1".
2020. Available online: https://www2.deloitte.com/content/dam/Deloitte/cn/Documents/finance/deloitte-cn-fueling-
the-future-of-mobilitv-en-200101 .pdf.

112 Ibid.

113 Burke, Andrew, Marshall Miller, Anish Sinha, et. al. "Evaluation of the Economics of Battery-Electric and Fuel
Cell Trucks and Buses: Methods, Issues, and Results". August 1, 2022. Available online:
https://escholarship.org/uc/item/lg89p8dn.

114 Deloitte China. "Fueling the Future of Mobility: Hydrogen and fuel cell solutions for transportation, Volume 1".
2020. Available online: https://www2.deloitte.com/content/dam/Deloitte/cn/Documents/finance/deloitte-cn-fueling-
the-future-of-mobilitv-en-200101 .pdf.

115 Marcinkoski, Jason et. al. "DOE Advanced Truck Technologies: Subsection of the Electrified Powertrain
Roadmap—Technical Targets for Hydrogen-Fueled Long-Haul Tractor-Trailer Trucks. October 31, 2019. Available
online: https://www.hvdrogen.energv.gov/pdfs/19006 hydrogen class8 long haul truck targets.pdf.

267

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116 Islam, Ehsan Sabri, Ram Vijayagopal, Aymeric Rousseau. "A Comprehensive Simulation Study to Evaluate
Future Vehicle Energy and Cost Reduction Potential", Report to the U.S. Department of Energy, Contract
ANL/ESD-22/6, October 2022. See Medium- and heavy-duty vehicles (techno-economic analysis with BEAN).
Available online: https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/.

117 Sharpe, B., Basma, H. "A meta-study of purchase costs for zero-emission trucks". International Council on Clean
Transportation. February 17, 2022. Available online: https://theicct.org/wp-content/uploads/2022/Q2/purchase-cost-
ze-trucks-feb22-l .pdf.

118 Ibid.

119 Marcinkoski, Jason et. al. "DOE Advanced Truck Technologies: Subsection of the Electrified Powertrain
Roadmap—Technical Targets for Hydrogen-Fueled Long-Haul Tractor-Trailer Trucks. October 31, 2019. Available
online: https://www.hvdrogen.energy.gov/pdfs/19006 hydrogen class8 long haul truck targets.pdf.

120 Kenworth. Flyer: "Kenworth Toyota Fuel Cell Electric Vehicle—T680 Fuel Cell Electric Vehicle". August 25,

2021. Available online: https://www.kenworth.com/media/voffdzok/ata-fuel-cell-flver-08-25-2021-v2.pdf.

121 Voelcker, John. "Toyota and Kenworth to build 10 fuel-cell semis for LA port duty". Green Car Reports. January
9, 2019. Available online: https://www.greencarreports.eom/news/l 120765 tovota-and-kenworth-to-build-10-fuel-
cell-semis-for-la-port-dutv.

122 U.S. Department of Energy. "DOE National Clean Hydrogen Strategy and Roadmap". Draft September 2022.
Available online: https://www.hvdrogen.energv.gov/pdfs/clean-hvdrogen-strategv-roadmap.pdf.

123 U.S. Department of Energy. "DOE National Clean Hydrogen Strategy and Roadmap". Draft September 2022.
Available online: https://www.hvdrogen.energv.gov/pdfs/clean-hvdrogen-strategy-roadmap.pdf.

124 U.S. Department of Energy. "Pathways to Commercial Liftoff: Clean Hydrogen". March 2023. Available online:
https://liftoff.energy.gOv/wp-content/uploads/2023/03/20230320-Liftoff-Clean-H2-vPUB.pdf.

125 Islam, Ehsan Sabri, Ram Vijayagopal, Aymeric Rousseau. "A Comprehensive Simulation Study to Evaluate
Future Vehicle Energy and Cost Reduction Potential", Report to the U.S. Department of Energy, Contract
ANL/ESD-22/6, October 2022. See Medium- and heavy-duty vehicles (techno-economic analysis with BEAN).
Available online: https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/.

126 Hydrogen Tools "Energy Equivalency of Fuels (LHV)". U.S. Department of Energy: Pacific Northwest National
Laboratory. Available online: https://h2tools.org/hvarc/hvdrogen-data/energv-equivalencv-fuels-lhv.

127 Islam, Ehsan Sabri. Ram Vijayagopal, Ayman Moawad, Namdoo Kim, Benjamin Dupont, Daniela Nieto Prada,
Aymeric Rousseau, "A Detailed Vehicle Modeling & Simulation Study Quantifying Energy Consumption and Cost
Reduction of Advanced Vehicle Technologies Through 2050," Report to the US Department of Energy, Contract
ANL/ESD-21/10, October 2021. See previous reports and analysis: 2021. Available online:
https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/.

128 Hunter, Chad, Michael Penev, Evan Reznicek, Jason Lustbader, Alicia Birkby, and Chen Zhang. "Spatial and
Temporal Analysis of the Total Cost of Ownership for Class 8 Tractors and Class 4 Parcel Delivery Trucks".
National Renewable Energy Lab. September 2021. Available online: https://www.nrel.gov/docs/fv21osti/71796.pdf.

129 Ledna et. al. "Decarbonizing Medium- & Heavy-Duty On-Road Vehicles: Zero-Emission Vehicles Cost
Analysis". U.S. Department of Energy, National Renewable Energy Laboratory. March 2022. Available online:
https://www.nrel. gov/docs/fv22osti/82081 .pdf.

130 Larsen, John et. al. "Assessing the Climate and Clean Energy Provisions in the Inflation Reduction Act".
Rhodium Group. August 12, 2022. Available online: https://rhg.com/research/climate-clean-energv-inflation-
reduction-act/.

131 Heid, Bernd et. al. "Five charts on hydrogen's role in a net-zero future". McKinsey Sustainability. October 25,

2022. Available online: https://www.mckinsev.com/capabilities/sustainabilitv/our-insights/five-charts-on-
hvdrogens-role-in-a-net-zero-future.

132 Zhou, Yuanrong, et. al. "Current and future cost of e-kerosene in the United States and Europe". Working Paper
2022-14: The International Council on Clean Transportation. March 2022. Available online: https://theicct.org/wp-
content/uploads/2022/02/fuels-us-europe-current-future-cost-ekerosene-us-europe-mar22.pdf.

133 Hydrogen Council. "Path to hydrogen competitiveness: A cost perspective". January 20, 2020. Available online:
https://hvdrogencouncil.com/wp-content/uploads/2020/01/Path-to-Hvdrogen-Competitiveness Full-Studv-l.pdf.

134 Rustagi, Neha et. al. Record 18003: "Current Status of Hydrogen Delivery and Dispensing Costs and Pathways to
Future Cost Reductions". U.S. Department of Energy. December 17, 2018. Available online:
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268

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135 Islam, Ehsan Sabri. Ram Vijayagopal, Ayman Moawad, Namdoo Kim, Benjamin Dupont, Daniela Nieto Prada,
Aymeric Rousseau, "A Detailed Vehicle Modeling & Simulation Study Quantifying Energy Consumption and Cost
Reduction of Advanced Vehicle Technologies Through 2050," Report to the US Department of Energy, Contract
ANL/ESD-21/10, October 2021. See previous reports and analysis: 2021. Available online:
https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/.

136 Burnham, A., Gohlke, D., Rush, L., Stephens, T., Zhou, Y., Delucchi, M. A., Birky, A., Hunter, C., Lin, Z., Ou,
S., Xie, F., Proctor, C., Wiryadinata, S., Liu, N., Boloor, M. "Comprehensive Total Cost of Ownership
Quantification for Vehicles with Different Size Classes and Powertrains". Argonne National Laboratory. April 1,
2021. Available online: https://publications.anl.gov/anlpubs/2021/05/167399.pdf.

137 Hunter, Chad, Michael Penev, Evan Reznicek, Jason Lustbader, Alicia Birkby, and Chen Zhang. "Spatial and
Temporal Analysis of the Total Cost of Ownership for Class 8 Tractors and Class 4 Parcel Delivery Trucks".
National Renewable Energy Lab. September 2021. Available online: https://www.nrel.gov/docs/fv21osti/71796.pdf.

138 Burke, Andrew, Marshall Miller, Anish Sinha, et. al. "Evaluation of the Economics of Battery-Electric and Fuel
Cell Trucks and Buses: Methods, Issues, and Results". August 1, 2022. Available online:
https://escholarship.org/uc/item/lg89p8dn.

139 Wang, G., Miller, M., and Fulton, L." Estimating Maintenance and Repair Costs for Battery Electric and Fuel
Cell Heavy Duty Trucks, 2022. Available online:

https://escholarship.org/content/qt36c08395/qt36c08395 noSplash 589098e470b036b3010eae00f3b7b618.pdf?t=r6
zwib.

140 Nicholas, Michael. "Estimating electric vehicle charging infrastructure costs across major U.S. metropolitan
areas". The International Council on Clean Transportation. 2019. Available online:
https://theicct.org/sites/default/files/publications/ICCT EV Charging Cost 20190813.pdf.

141 U.S. Department of Energy. "Costs Associated with Non-Residential Electric Vehicle Supply Equipment". 2015.
Available online: https://afdc.energy.gOv/files/u/publication/evse cost report 2015.pdf.

142 Ibid.

143 Schey, Stephen, Kang-Ching Chu, and John Smart. "Breakdown of Electric Vehicle Supply Equipment
Installation Costs. Idaho National Laboratory." 2022. Accessed March 13, 2023.
https://inldigitallibrary. inl. gov/ sites/sti/sti/Sort_63124.pdf.

144 Nicholas, Michael. "Estimating electric vehicle charging infrastructure costs across major U.S. metropolitan
areas". The International Council on Clean Transportation. 2019. Available online:
https://theicct.org/sites/default/files/publications/ICCT EV Charging Cost 20190813.pdf.

145 Borlaug, B., Muratori, M., Gilleran, M. et al. "Heavy-duty truck electrification and the impacts of depot charging
on electricity distribution systems". Nat Energy 6, 673-682 (2021). Available online:

https ://www. nature. com/articles/s41560-021-00855-0.

146 Nicholas, Michael. "Estimating electric vehicle charging infrastructure costs across major U.S. metropolitan
areas". The International Council on Clean Transportation. 2019. Available online:
https://theicct.org/sites/default/files/publications/ICCT EV Charging Cost 20190813.pdf.

147 Nelder, Chris and Emily Rogers. "Reducing EV Charging Infrastructure Costs". Rocky Mountain Institute. 2019.
Available online: https://rmi.org/wp-content/uploads/2020/01/RMI-EV-Charging-Infrastructure-Costs.pdf.

148 Vermont Energy Investment Corporation. "Electric School Bus Charging Equipment Installation Guide". August
2017. Available online: https://www.veic.org/Media/Default/documents/resources/reports/electric-school-bus-
charging-equipment-installation-guide.pdf.

149 Bauer, Gordon, Chih-Wei Hsu, Mike Nicholas, and Nic Lutsey. "Charging Up America: Assessing the Growing
Need for U.S. Charging Infrastructure Through 2030". The International Council on Clean Transportation, July
2021. Available online: https://theicct.org/wp-content/uploads/2021/12/charging-up-america-iul2021.pdf.

150 Minjares, Ray, Felipe Rodriguez, Arijit Sen, and Caleb Braun. "Infrastructure to support a 100% zero-emission
tractor-trailer fleet in the United States by 2040". ICCT, September 2021. Available online:
https://theicct.org/sites/default/files/publications/ze-tractor-trailer-fleet-us-hdvs-sept21.pdf.

151 Bauer, Gordon, Chih-Wei Hsu, Mike Nicholas, and Nic Lutsey. "Charging Up America: Assessing the Growing
Need for U.S. Charging Infrastructure Through 2030". The International Council on Clean Transportation, July
2021. Available online: https://theicct.org/wp-content/uploads/2021/12/charging-up-america-iul2021.pdf.

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152Zhang, Chen; Kotz, Andrew; Kelly, Kenneth "Heavy-Duty Vehicle Activity for EPA MOVES." National
Renewable Energy Laboratory. 2021. Available online: https://data.nrel.gov/submissions/168.

153 Zhang, Chen, Karen Ficenec, Andrew Kotz, Kenneth Kelly, Darrell Sonntag, Carl Fulper, Jessica Brakora,
Tiffany Mo, and Sudheer Ballare. "Heavy-Duty Vehicle Activity Updates for MOVES Using NREL Fleet DlSJA and

CE-CERT Data." Golden, CO: National Renewable Energy Laboratory. NREL/TP-5400-79509. 2021. Available

online: https://www.nrel.gov/docs/fy21 osti/79509.pdf.

154 Proterra. "New Proterra EV Charging Solutions Enable Full Fleet Electrification for Commercial Vehicles".
October 28, 2020. Available online: https://www.proterra.com/press-release/proterra-chargers-enable-fleet-

electrification/.

155 Agrawal, AJay. "Charge More EVs with Power Management". ChargePoint, EV Charging Innovation: July 18,

2017. Available online: https://www.chargepoint.com/blog/charge-more-evs-power-management.

156 Tesla. "Power Sharing Overview". Available online: https://www.tesla.com/support/gen-3-wall-connector-
power-sharing#overview.

157 Borlaug, B Muratori, M., Gilleran, M. et al. "Heavy-duty truck electrification and the impacts of depot charging
on electricity distribution systems". Nat Energy 6, 673-682 (2021). Available online:

https://www.nature.com/articles/s41560-021-00855-0.

158 National Renewable Energy Laboratory. "When Does Energy Storage Make Sense? It Depends." February 25,

2018. Available online: https://www.nrel.gov/state-local-tribal/blog/posts/when-does-energv-storage-make-sense-it-

depends.html.

159 California Department of Tax and Fee Administration. "Laws, Regulations and Annotations". Accessed October
2022. Available online: https://www.cdtfa.ca.gov/lawguides/vol3/dftr/dftr-regl432.html.

160 Brooker, Aaron, Alicia Birky, Evan Reznicek, Jeff Gonder Chad Hunter, Jason Lustbader, Chen Zhang, Lauren
Sittler, Arthur Yip, Fan Yang, and Dong-Yeon Lee. "Vehicle Technologies and Hydrogen and Fuel Cell

Technologies Research and Development Programs Benefits Assessment Report for 2020." Golden, CO: National

Renewable Energy Laboratory. NREL/TP-5400-79617. 2021. https://www.nrel.gov/docs/fy21osti/79617.pdf.

161 Islam Ehsan Sabri, Ram Vijayagopal, Aymeric Rousseau. "A Comprehensive Simulation Study to Evaluate
Future Vehicle Energy and Cost Reduction Potential", Report to the U.S. Department of Energy, Contract

ANL/ESD-22/6, October 2022. See Medium- and heavy-duty vehicles (techno-economic analysis with BEAN).

Available online: https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/.

162 U.S. Environmental Protection Agency. 81 FR 73558 (Oct 25, 2016).

163 National Renewable Energy Laboratory. "Market Penetration of New Technologies." February 1993. Available
at: https://www.nrel.gov/docs/legosti/old/4860.pdf.

164 Mitchell, George. Memorandum to docket EPA-HQ-OAR-2022-0985. " ACT Research Co. LLC. "Charging
Forward" 2520-2040 BEV & FCEV Forecast & Analysis, updated December 2021.

165 Oak Ridge National Laboratory. "MA3T-TruckChoice." June 2021. Available at:

https://www.energv.gov/sites/default/files/2021-07/van021 lin 2021 o 5-28 1126pm LR FINAL ML.pdf.

166 Oak Ridge National Laboratory. "Transportation Energy Evolution Modeling (TEEM) Program."
https://www.energv.gov/eere/vehicles/articles/transportation-energv-evolution-modeling-teem-program-l

167 National Renewable Energy Laboratory. T3CO: Transportation Technology Total Cost of Ownership. Available
at: https://www.nrel.gov/transportation/t3co.html.

i(38 Argonne National Laboratory. BEAN: Benefits Analysis, https://vms.taps.anl.gov/tools/bean/.

169 Pacific Northwest National Laboratory. GCAM: Global Change Analysis Model.
https://gcims.pnnl.gov/modeling/gcam-global-change-analysis-model

170 Robo, Ellen and Dave Seamonds. Technical Memo to Environmental Defense Fund: Analysis of Alternative
Medium- and Heavy-Duty Zero-Emission Vehicle Business-As-Usual Scenarios. ERM. August 19, 2022. Available

online: https://www.erm.eom/contentassets/154d08e0d0674752925cd82c66b3e2bl/edf-zev-baseline-technical-

memo-16may2022.pdf.

171 ICCT and Energy Innovation. "Analyzing the Impact of the Inflation Reduction Act on Electric Vehicle Uptake
in the United States'. January 2023. Available online: https://theicct.org/wp-content/uploads/2023/01/ira-impact-

evs-us-j an23 -2. pdf.

172 Al-AlawL Baha M., Owen MacDonnell Cristiano Facanha. "Global Sales Targets for Zero-Emission Medium -
and Heavy-Duty Vehicles—Methods and Application". February 2022. Available online:

https://globaldrivetozero.org/site/wp-content/uploads/2022/02/CALSTART_Global-Sales_White-Paper.pdf.

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173173 Mitchell, George. Memorandum to docket EPA-HQ-OAR-2022-0985. " ACT Research Co. LLC. "Charging
Forward" 2020-2040 BEV & FCEV Forecast & Analysis, updated December 2021.

174 National Renewable Energy Laboratory. T3CO: Transportation Technology Total Cost of Ownership. Available
at: https://www.nrel.gov/transportation/t3co.html.

175 Oak Ridge National Laboratory. "MA3T-TruckChoice." June 2021. Available at:

https://www.energv.gov/sites/default/files/2021-07/van021 lin 2021 o 5-28 1126pm LR FINAL ML.pdf

176 Pacific Northwest National Laboratory. GCAM: Global Change Analysis Model.
https://gcims.pnnl.gov/modeling/gcam-global-change-analvsis-model

177 Robo, Ellen and Dave Seamonds. Technical Memo to Environmental Defense Fund: Analysis of Alternative
Medium- and Heavy-Duty Zero-Emission Vehicle Business-As-Usual Scenarios. ERM. August 19, 2022. Available
online: https://www.erm.com/contentassets/154d08e0d0674752925cd82c66b3e2bl/edf-zev-baseline-technical-
memo- 16mav2022.pdf.

178ICCT and Energy Innovation. "Analyzing the Impact of the Inflation Reduction Act on Electric Vehicle Uptake
in the United States". January 2023. Available online: https://theicct.org/wp-content/uploads/2023/01/ira-impact-
evs-us-i an23 -2. pdf.

179 Al-Alawi, Baha M., Owen MacDonnell, Cristiano Facanha. "Global Sales Targets for Zero-Emission Medium-
and Heavy-Duty Vehicles—Methods and Application". February 2022. Available online:
https://globaldrivetozero.org/site/wp-content/uploads/2022/02/CALSTART Global-Sales White-Paper.pdf.

180 North American Council for Freight Efficiency (NACFE). "Electric Trucks Have Arrived: The Use Case for
Heavy-Duty Regional Haul Tractors—Run on Less Electric Report". May 5, 2022. Figure 16. Available online:
https://nacfe.org/wp-content/uploads/edd/2022/05/HD-Regional-Haul-Report-FINAL.pdf..

181 U.S. Department of Transportation, Federal Highway Administration. "Federal Size Regulations for Commercial
Motor Vehicles". Available online:

https://ops.fhwa.dot.gov/freight/publications/size regs final rpt/index.htm#width

182 Nair, Vishnu; Sawyer Stone; Gary Rogers; Sajit Pillai; Roush Industries, Inc. "Technical Review: Medium and
Heavy Duty Electrification Costs for MY 2027-2030." February 2022. Page 18. Last accessed on February 9, 2023
at https://blogs.edf.org/climate41 l/files/2022/02/EDF-MDHD-Electrification-vl .6 20220209.pdf.

183 Hall, Dale and Nic Lutsey. "Estimating the Infrastructure Needs and Costs for the Launch of Zero-Emission
Trucks." February 2019. Page 4. Last accessed on February 9, 2023 at https://theicct.org/wp-
content/uploads/2021 /06/ICCT EV HDVs Infrastructure 20190809.pdf.

184 Kahn, Ari, et. al. "The Inflation Reduction Act Will Help Electrify Heavy-Duty Trucking". Rocky Mountain
Institute. August 25, 2022. Available online: https://rmi.org/inflation-reduction-act-will-help-electrifv-heavy-duty-
trucking/.

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Chapter 3 Program Costs

In this chapter, EPA presents the costs we estimate would be incurred by manufacturers and
purchasers of HD vehicles impacted by the proposed standards. We also present the social costs
of the proposed standards. Our analyses characterize the costs of the technology package
described in section II.D of the preamble; however, as we note there, manufacturers may elect to
comply using a different combination of HD vehicle and engine technologies than what we have
identified. We present these costs not only in terms of the upfront incremental technology costs
difference between an HD BEV or FCEV powertrain and a comparable HD ICE powertrain1 as
presented in Chapter 2 of this DRIA, but also how those costs would change in years following
implementation due to learning-by-doing effects as described in Chapter 3.2.1 below. These
technology costs are presented in terms of direct manufacturing costs (DMC) and associated
indirect costs (i.e., research and development (R&D), administrative costs, marketing, and other
costs of running a company). These direct and indirect costs when summed are referred to as
"technology package costs" in this section, and represent the estimated costs incurred by
manufacturers (i.e., regulated entities), to comply with the proposed standards.11

The analysis also includes estimates of the operating costs associated with HD ICE vehicles,
BEVs, and FCEVs. These operating costs do not represent compliance costs for manufacturers,
but rather estimated costs incurred by users of MY 2027 and later HD vehicles.111 All costs are
presented in 2021 dollars unless noted otherwise.

In this chapter, we present the costs we estimate would be incurred by manufacturers and
purchasers of HD vehicles impacted by the proposal. We break the costs into the following
categories and subcategories:

1) Technology Package Costs, which are the sum of direct manufacturing costs (DMC) and
indirect costs. This may also be called the package retail price equivalent or "package
RPE." This includes:

a. DMC, which include the costs of materials and labor to produce a product or
piece of technology.

b. Indirect costs, which include research and development (R&D), warranty,
corporate operations (such as salaries, pensions, health care costs, dealer support,
and marketing), and profits. As described below, we estimate indirect costs using
retail price equivalent (RPE) markups.

I Baseline vehicles are ICE vehicles meeting the Phase 2 standards discussed in DRIA chapter 2.2.2 and the Low
NOx standards discussed in DRIA chapter 2.3.2.

II More accurately, these technology costs represent costs that manufacturers are expected to attempt to recapture via
new vehicle sales. For example, profits are included in the indirect cost calculation. Clearly, profits are not a cost of
compliance—EPA is not imposing new regulations that would require manufacturers to make a profit. However, we
expect that manufacturers will want to make profits. As such, we expect that manufacturers will make a profit on the
vehicles they sell and we carry those profits as part of the estimated technology costs.

III Importantly, the proposed GHG standards would apply only to new, MY 2027 and later HD vehicles. The legacy
fleet is not subject to the new requirements and, therefore, users of prior model year vehicles would not incur the
operating costs we estimate.

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2) Manufacturer Costs, or "manufacturer RPE," which is the package RPE less any
applicable battery tax credits. This includes:

a. Package RPE, as described above. Traditionally, the package RPE is the
manufacturer RPE in EPA cost analyses.

b. Battery tax credits from IRA section 13502, "Advanced Manufacturing
Production Credit," which serve to reduce manufacturer costs. The battery tax
credit is described further in preamble Sections I and II and Chapters 1 and 2 of
the DRIA.

3) Purchaser Costs, which are the sum of purchaser upfront vehicle costs and operating
costs. This includes:

a. Manufacturer RPE. In other words, the purchaser incurs the manufacturer's
package costs less any applicable battery tax credits. As described above, we refer
to this as the "manufacturer RPE" in relation to the manufacturer and, at times,
the "purchaser RPE" in relation to the purchaser. These two terms are equivalent
in this analysis.

b. Vehicle tax credit from IRA section 13403, "Qualified Commercial Clean
Vehicles," which serve to reduce purchaser costs. The vehicle tax credit is
described further in preamble Sections I and II and Chapters 1 and 2 of the DRIA.

c. Electric Vehicle Supply Equipment (EVSE) costs, which are the costs associated
with charging equipment. Our EVSE cost estimates include indirect costs so are
sometimes referred to as "EVSE RPE."

d. Purchaser upfront vehicle costs, which include the manufacturer (also referred to
as purchaser) RPE plus EVSE costs less any applicable vehicle tax credits.

e. Operating costs, which include fuel costs, costs for diesel exhaust fluid (DEF),
and maintenance and repair costs.

4) Social Costs, which are the sum of package RPE, EVSE RPE, and operating costs and
computed on at a fleet level on an annual basis. This includes:

a. Package RPE which, as described above, excludes applicable tax credits.

b. EVSE RPE.

c. Operating costs which include pre-tax fuel costs, DEF costs and maintenance and
repair costs.

d. Note that fuel taxes and battery and vehicle tax credits are not included in the
social costs. Taxes and tax credits are transfers as opposed to social costs.

We describe these costs and present our cost estimates in the text that follows. All costs are
presented in 2021 dollars, unless noted otherwise. Table 3-1 shows the gross domestic product
price deflators used to adjust to 2021 dollars. We used the MOVES scenarios discussed in DRIA

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Chapter 4, the reference, proposed and alternative cases,1V to compute operating costs as well as
social costs on an annual basis. Our costs and tax credits estimated on a per vehicle basis do not
change based between the reference and proposal cases, but the estimated vehicle populations
that would be ICE vehicles, BEVs or FCEVs do change between the reference and proposal
cases. We expect an increase BEVs and FCEVs sales and decrease of ICE vehicle sales in the
proposal compared to the reference case and these changes in vehicle populations are the
determining factor for total cost differences between the reference and proposal cases.

But first we discuss the relevant IRA tax credits and how we have considered them in our
estimates. Note that the analysis that follows sometimes presents undiscounted costs and
sometimes presents discounted costs. We discount future costs and benefits to properly
characterize their value in the present or, as directed by the Office of Management and Budget in
Advisory Circular A-4, in the year costs and benefits begin.1 In Circular A-4, OMB directs use of
both 3 and 7 percent discount rates as we have done with some exceptions as described below.2

Table 3-1: GDP Price Deflators* Used to Adjust Costs to 2021 Dollars

Cost Basis Year

Conversion Factor

2017

1.099

2018

1.073

2019

1.054

2020

1.042

2021

1.000

* Based on the National Income and

Product Accounts, Table 1.1.9 Implicit
Price Deflators for Gross Domestic
Product, Bureau of Economic Analysis,

U.S. Department of Commerce, April
28, 2022.

The cost analysis is done using a tool written in Python and may be found in the docket for
this action. The Python tool, along with some supporting documentation, may be found in the
docket for this action and on our website.3

3.1 IRA Tax Credits

Our cost analysis quantitatively includes consideration of two IRA tax credits, specifically the
battery tax credit and the vehicle tax credit discussed in Sections I.C.2 and II.D.5 of the preamble
and Chapters 1.3.2 and 2.4.3 of the DRIA. We note that a detailed discussion of how these tax
credits were considered in our consideration of costs in our technology packages may be found
in Section II.D.5 of the preamble and Chapter 2.4.3 of the DRIA. The battery tax credits are
expected to reduce manufacturer costs, and in turn purchaser costs, as discussed in Chapter 3.3.2.
The vehicle tax credit is expected to reduce purchaser costs, as discussed in Chapter 3.4.2. For
the cost analysis discussed in this chapter, both the battery tax credit and vehicle tax credit were
estimated for MYs 2027 through 2032 and then aggregated for each MOVES source type and
regulatory class.

lv As discussed in DRIA Chapter 4.2.2, the reference case is a no-action scenario that represents emissions in the
U.S. without the proposed rulemaking. The proposed and alternative cases represented emissions in the U.S. for
each potential set of GHG standards.

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3.2 Technology Package Costs

Technology package costs include estimated technology costs associated with compliance
with the proposed MY 2027 and later CO2 emission standards. Individual technology piece costs
are presented in Chapter 2 of the DRIA and the costs presented there represent costs in the first
year that a new standard is implemented. For each of the model years following the first year of
implementation, we have applied a learning effect to the technology costs for vehicles we expect
to be sold in that model year which represent the cost reductions expected to occur via the
"learning by doing" phenomenon.4 The "learning by doing" phenomenon is the process by which
doing something over and over results in learning how to do that thing more efficiently which, in
turn, leads to reduced resource usage, i.e., cost savings. This provides a year-over-year cost for
each technology as applied to new vehicle production, which is then used to calculate total
technology package costs of the proposed standards.

This technology package cost calculation approach presumes that the expected technologies
would be purchased by the vehicle original equipment manufacturers (OEMs) from their
suppliers. So, while the DMC estimates for the vehicle manufacturer in Chapter 3.2.1 include the
indirect costs and profits incurred by the supplier, the indirect cost markups we apply in Chapter
3.2.2 cover the indirect costs incurred by vehicle manufacturers to incorporate the new
technologies into their vehicles and profit margins for the vehicle manufacturers typical of the
heavy-duty vehicle industry. To address these vehicle manufacturer indirect costs, we applied
industry standard "retail price equivalent" (RPE) markup factors to the DMC to estimate vehicle
manufacturer indirect costs associated with the new technology. These factors represent an
average price, or retail price equivalent (RPE), for products assuming all products recapture costs
in the same way. We recognize that this is rarely the case since manufacturers typically price
certain products higher than average and others lower than average (i.e., they cross-subsidize).
For that reason, the RPE should not be considered a price but instead should be considered more
like the average cross-subsidy needed to recapture both costs and profits to support ongoing
business operations. Both the learning effects applied to direct costs and the application of
markup factors to estimate indirect costs are consistent previous HD GHG rules with the cost
estimation approaches used in EPA's past transportation-related regulatory programs.5 The sum
of the DMC and indirect costs represents our estimate of technology "package costs" or
"package RPE" per vehicle year-over-year. These per vehicle technology package costs
multiplied by estimated sales then represent the total technology package-related costs for
manufacturers (total package costs or total package RPE) associated with the proposed HD
vehicle CO2 standards.

3.2.1 Direct Manufacturing Costs

To produce a unit of output, manufacturers incur direct and indirect manufacturing costs.
DMC includes cost of materials and labor costs. Indirect manufacturing costs are discussed in the
following section, Chapter 3.2.2. The DMCs presented here include the incremental technology
piece costs associated with compliance with the proposed standards as compared to the
technology piece costsv associated with the comparable baseline vehicle," which could be

v We sometimes use the term "piece cost" simply to refer to the cost associated with a piece of technology. That
could be a turbocharger, it could be an EGR valve, it could also be a BEV powertrain in place of an ICE powertrain.
V1 Baseline vehicles are ICE vehicles meeting the Phase 2 GHG standards as discussed in DRIA Chapter 2.2.2 and
the HD2027 criteria pollutant standards as discussed in DRIA Chapter 2.3.2.

275

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thought of as the technology piece costs of replacing an ICE powertrain with a BEV or FCEV
powertrain.

Throughout this discussion, when we refer to reference case costs we are referring to our cost
estimate of the no-action case (impacts absent this proposed rule) which include costs associated
with replacing a comparable ICE powertrain with a BEV or FCEV powertrain for ZEV adoption
rates in the reference case.

We have estimated the DMC by starting with the cost of the baseline vehicle, removing the
cost of a comparable ICE powertrain, and adding the cost of a BEV or FCEV powertrain. We
calculated the DMC per vehicle aggregated by MOVES source type and regulatory class via a
technology-sales-weighted average using the DMC and adoption rates presented in Chapter 2.
This calculation depended on the DMC for each of the 101 Vehicle IDs in HD TRUCS and the
mix (i.e., the relative proportions) of those Vehicle IDs in each combination of source type and
regulatory class, which is dependent on overall sales and technology adoption rates for each
Vehicle ID. DMCs for MY 2027 for each of the 101 Vehicle IDs in HD TRUCS are shown in
Chapter 2.8.2 and the learning effect described later in this section was used to project costs to
future MYs. Sales for each of the 101 Vehicle IDs in HD TRUCS are shown in Chapter 2.2.3.
Technology adoption rates for MYs 2027 and 2032 for each of the 101 Vehicle IDs in HD
TRUCS are shown in Chapter 2.8.3. For the purposes of this cost analysis, we interpolated these
adoption rates following the methodology described in Chapter 2.9.1 to calculate the adoption
rates of Vehicle IDs in each combination of source type and regulatory class for MYs 2028-
2031.

For the Combination Short-Haul and Combination Long-Haul Truck source types, the VMT
modeled in MOVES differed from the VMT used in HD TRUCS; some of the HD TRUCS
Vehicle IDs were sized for lower VMT than what was used in MOVES due to differences in the
references used to inform VMT for these tools. For the purposes of this cost analysis, we
estimated DMC based on HD TRUCS Vehicle IDs whose VMT were most similar to the VMT
in MOVES for the same source type and regulatory class. We did this to attribute appropriate
vehicle technology costs in this analysis to the VMT modeled in MOVES, and thus the operating
costs calculated in this analysis. We selected HD TRUCS Vehicle IDs 81Tractor_DC_C17_R and
82Tractor_DC_C18_R to represent Class 6-7 and Class 8 Combination Short-Haul Trucks,
respectively. We selected HD TRUCS Vehicle ID 79Tractor_SC_C18_R to represent all
Combination Long-Haul Trucks.

In the reference case in MOVES, ZEVs under source type 53 (Single Unit Long-Haul Trucks)
are FCEVs. In our HD TRUCS analysis used to develop the technology package described in
DRIA Chapter 2, we determined that BEV technology was suitable for vehicles with source type
53. As explained in DRIA Chapter 4.3.2, we modeled the proposal in MOVES by adding ZEVs
beyond the reference case levels with BEVs or FCEVs as projected in our technology package,
and we did not decrease any BEV or FCEV populations from the reference case. Thus, for source
type 53 in MOVES, we estimated powertrain replacement costs for the population of FCEVs in
the reference case and powertrain replacement costs for the population of BEVs added beyond
the reference case resulting from the proposed standards. For the source type 53 reference case
FCEV population, we used the costs for FCEV and ICE vehicles for Vehicle IDs
06T_Box_Cl8_R, 08T_Box_C16-7_R, 66V_Step_C12b-3_MP, and 95T_Utility_C14-5_Rto
calculate the powertrain replacement costs for regulatory classes 47 (Class 8), 46 (Class 6-7), 41

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(Class 2b-3), and 42 (Class 4-5), respectively. For regulatory classes 42, 46, and 47, these
Vehicle IDs were the only options available in HD TRUCS. For regulatory class 41, we selected
66V_Step_C12b-3_MP because it had the median cost among the three available options; we
note that the FCEV powertrain add costs vary by only about 3 percent. For the source type 53
BEV population in the proposal scenario, we calculated powertrain replacement costs as
described earlier in this section. Please refer to Chapter 4 for further discussion on differences
between the reference case and our technology package.

Net incremental costs reflect adding the total costs of components added to the powertrain to
make it a BEV or FCEV, as well as removing the total costs of components removed from a
comparable ICE vehicle to make it a BEV or FCEV.

Chapter 4 of the DRIA contains a description of the MOVES vehicle source types and
regulatory classes. In short, we estimate costs in MOVES for vehicle source types that have both
regulatory class populations and associated emission inventories. Also, throughout this section,
LHD refers to light heavy-duty vehicles, MHD refers to medium heavy-duty vehicles, and HHD
refers to heavy heavy-duty vehicles.

For some of the BEV, FCEV and ICE vehicle technologies considered in this analysis,
manufacturer learning effects would be expected to play a role in the actual end costs. The
"learning curve" or "experience curve" describes the reduction in unit production costs as a
function of accumulated production volume. In theory, the cost behavior the learning curve
describes applies to cumulative production volume measured at the level of an individual
manufacturer, although it is often assumed—as EPA has done in past regulatory analyses—to
apply at the industry-wide level, particularly in industries that utilize many common technologies
and component supply sources. We believe there are indeed many factors that cause costs to
decrease over time. Research in the costs of manufacturing has consistently shown that, as
manufacturers gain experience in production, they are able to apply innovations to simplify
machining and assembly operations, use lower cost materials, and reduce the number or
complexity of component parts. All of these factors allow manufacturers to lower the per-unit
cost of production (i.e., "learning by doing" the manufacturing learning curve).6

A steeper learning algorithm was applied for only BEV or FCEV powertrain technologies
costs, as these are considered to be new or emerging technologies compared to the ICE vehicle
technologies. The learning algorithms applied to each scenario for BEV or FCEV powertrain
costs are summarized in Table 3-2. The proposal, alternative and reference case all used the same
learning factors presented in Table 3-2.

The direct manufacturing costs for BEV, FCEV and ICE powertrains were adjusted to
account for learning effects going forward from the first year of implementation, in an approach
similar to the one taken for the HD GHG Phase 2 final rule. Static learning factors were applied
to BEV and FCEV powertrain add costs as well as ICE powertrain delete costsvu for the
reference, proposed, and alternative scenarios and for each model year as shown in Table 3-2.
These learning factors were generated with the expectation that learning on ICE technologies
would slow, relative to their traditional rates, in favor of a focus on BEV and FCEV

vn Powertrain add costs are the total costs of all components added to a powertrain to make it a BEV or FCEV. ICE
powertrain delete costs are the total costs savings realized from removing all of the ICE powertrain components
from a vehicle.

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technologies. The resultant direct manufacturing costs and how those costs are expected to
reduce over time are presented in Chapter 3.3.3 on a total cost basis.

Table 3-2: Learning Curve applied to BEV, FCEV and ICE Powertrain Costs in the Reference, Proposal and

Alternative Scenarios

Model
Year

BEV and FCEV

Powertrain
Learning Scalar

ICE
Powertrain
Learning
Scalar

2027

1.000

2028

0.921

0.990

2029

0.866

0.990

2030

0.824

0.990

2031

0.791

0.980

2032

0.764

0.980

2033

0.741

0.980

2034

0.721

0.970

2035

0.704

0.970

2036

0.688

0.970

2037

0.674

0.960

2038

0.662

0.960

2039

0.650

0.960

2040

0.640

0.950

2041

0.630

0.950

2042

0.621

0.950

2043

0.612

0.950

2044

0.605

0.940

2045

0.597

0.940

2046

0.590

0.940

2047

0.584

0.940

2048

0.578

0.930

2049

0.572

0.930

2050

0.566

0.930

2051

0.561

0.920

2052

0.556

0.920

2053

0.551

0.920

2054

0.546

0.920

2055

0.542

0.920

3.2.2 Indirect Manufacturing Costs

Indirect manufacturing costs are all the costs associated with producing the unit of output that
are not direct manufacturing costs - for example, they may be related to research and
development (R&D), warranty, corporate operations (such as salaries, pensions, health care
costs, dealer support,, and marketing) and profits. An example of a R&D cost for this proposal
includes the engineering resources required to develop a battery state of health monitor as
described in preamble Section III.B. 1. An example of a warranty cost is the future cost covered
by the manufacturer to repair defective BEV or FCEV components and meet the warranty

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requirements proposed in Section III.B.2 of the preamble. Indirect costs are generally recovered
by allocating a share of the indirect costs to each unit of goods sold. Although direct costs can be
allocated to each unit of goods sold, it is more challenging to account for indirect costs allocated
to a unit of goods sold. To ensure that regulatory analyses capture the changes in indirect costs,
markup factors (which relate total indirect costs to total direct costs) have been developed and
used by EPA and other stakeholders. These factors are often referred to as RPE multipliers and
are typically applied to direct costs to estimate indirect costs. RPE multipliers provide, at an
aggregate level, the proportionate share of revenues relative shares of revenue where:

Revenue = Direct Costs + Indirect Costs

so that:

Revenue/Direct Costs = 1 + Indirect Costs/Direct Costs = RPE multiplier
and,

Indirect Costs = Direct Costs x (RPE - 1).

If the relationship between revenues and direct costs (i.e., RPE multiplier) can be shown to
equal an average value over time, then an estimate of direct costs can be multiplied by that
average value to estimate revenues, or total costs. Further, that difference between estimated
revenues, or total costs, and estimated direct costs can be taken as the indirect costs. Cost
analysts and regulatory agencies have frequently used these multipliers7 to predict the resultant
impact on costs associated with manufacturers' responses to regulatory requirements and we are
using cost multipliers in this analysis.

The markup factors are based on company filings with the Securities and Exchange
Commission for several engine and engine/truck manufacturers in the HD industry, as detailed in
a study by RTI International that was commissioned by EPA.8 The RPE factors developed by
RTI for HD engine manufacturers, HD truck manufacturers, and for the HD truck industry as a
whole are shown in Table 3-3.VU1 Also shown in Table 3-3 are the RPE factors developed by RTI
for light-duty vehicle manufacturers.9

Table 3-3: Retail Price Equivalent Factors in the Heavy-Duty and Light-Duty Industries

Cost Contributor

HD Engine
Manufacturer

HD Truck
Manufacturer

HD Truck
Industry

LD Vehicle
Industry

Direct manufacturing cost

1.00

Warranty

0.02

0.04

0.03

R&D

0.04

0.05

Other (admin, retirement, health, etc.)

0.17

0.22

0.29

0.36

Profit (cost of capital)

0.05

0.06

RPE

1.28

1.36

1.42

1.50

vm The engine manufacturers included were Hino and Cummins; the truck manufacturers included were PACCAR,
Navistar, Daimler and Volvo. Where gaps existed such as specific line items not reported by these companies due to
differing accounting practices, data from the Heavy Duty Truck Manufacturers Industry Report by Supplier
Relations LLC (2009) and Census (2009) data for Other Engine Equipment Manufacturing Industry (NAICS
333618) and Heavy Duty Truck Manufacturing Industry (NAICS 336120) were used to fill the gaps. This is detailed
in the study report at Appendix A. 1.

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For this analysis, EPA based indirect cost estimates for the replacement of HD CI engines (diesel
and compressed natural gas (CNG) MOVES fuel types) on the HD Truck Industry RPE value
shown in Table 3-3. We are using an RPE of 1.42 to compute the indirect costs associated with
the replacement of a diesel-fueled or CNG-fueled powertrain with a BEV or FCEV powertrain in
HD vehicles. For this analysis, EPA based indirect cost estimates for the replacement of HD SI
engines (gasoline MOVES fuel types) on the LD Truck Vehicle RPE value shown in Table 3-3
because the engines and vehicles more closely match those built by LD vehicle manufacturers.
We are using an RPE of 1.5 to compute the indirect costs associated with the replacement of a
gasoline-fueled powertrain with a BEV or FCEV powertrain in HD vehicles. The heavy-duty
vehicle industry is becoming more vertically integrated and the direct and indirect manufacturing
costs we are analyzing are those that reflect the technology packages costs OEMs would try to
recover at the purchaser level. For that reason, we believe the two respective vehicle industry
RPE values represent the most appropriate factors for this analysis.

3.2.3 Vehicle Technology Package RPE

Table 3-4 presents the fleet-wide incremental technology costs estimated for both the proposal
and alternative relative to the reference case for the projected adoption of ZEVs in our
technology package relative to the reference case on an annual basis. The costs shown in Table
3-4 reflect incremental costs of the technology package for the proposed CO2 standards as
compared to the baseline vehicle and, therefore, include removal of the ICE-specific components
and associated savings and then addition of the BEV or FCEV components and associated costs.

It is important to note that these are costs and not prices. We do not attempt to estimate how
manufacturers would price their products in the technology package costs. Manufacturers may
pass costs along to purchasers via price increases that reflect actual incremental costs to
manufacture a ZEV when compared to a comparable ICE vehicle. However, manufacturers may
also price products higher or lower than what would be necessary to account for the incremental
cost difference. For instance, a manufacturer may price certain products higher than necessary
and price others lower with the higher-priced products effectively subsidizing the lower-priced
products. This pricing strategy may be true in any market and is not limited to the heavy-duty
vehicle industry.

Table 3-4: Fleet-Wide Incremental Technology Costs for ZEVs, Millions of 2021 Dollars*

Calendar
Year

Vehicle Package

RPE for the
Proposed Option
Relative to the
Reference Case

Vehicle Package
RPE for the
Alternative Option
Relative to the
Reference Case

2027

$2,000

$920

2028

$1,800

$1,100

2029

$1,700

$1,000

2030

$2,000

$1,400

2031

$2,300

$1,400

2032

$2,000

$1,400

2033

$1,500

$960

280

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Calendar
Year

Vehicle Package

RPE for the
Proposed Option
Relative to the
Reference Case

Vehicle Package
RPE for the
Alternative Option
Relative to the
Reference Case

2034

$1,300

$810

2035

$1,000

$620

2036

$750

$440

2037

$620

$350

2038

$410

$200

2039

$220

$70

2040

$140

2041

-$40

-$120

2042

-$200

-$230

2043

-$360

-$340

2044

-$410

-$370

2045

-$550

-$480

2046

-$690

-$570

2047

-$820

-$670

2048

-$850

-$680

2049

-$970

-$770

2050

-$1,100

-$850

2051

-$1,100

-$860

2052

-$1,200

-$940

2053

-$1,300

-$1,000

2054

-$1,400

-$1,100

2055

-$1,500

-$1,200

PV, 3%

$9,000

$4,000

PV, 7%

$10,000

$5,400

* Values rounded to two significant digits; negative values
denote lower costs, i.e., savings in expenditures.

3.3 Manufacturer Costs

3.3.1 Relationship to Technology Package RPE

The manufacturer costs in EPA's past HD GHG rulemaking cost analysis on an average per
vehicle basis was only the average per vehicle technology package RPE described in Chapter
3.2.3. However, in the cost analysis for this proposal, we are also taking into account the IRA
battery tax credit in our estimates of manufacturer costs (also referred to in this section as
manufacturer's RPE), as we expect the battery tax credit to reduce manufacturer costs, and in
turn purchaser costs.

3.3.2 Battery Tax Credits

Table 3-5 shows the annual estimated fleet-wide battery tax credits from IRA section 13502,
"Advanced Manufacturing Production Credit," for the proposal relative to the reference case in
2021 dollars. These estimates were based on the detailed discussion in DRIA Chapter 2 of how
we considered battery tax credits. Both BEVs and FCEVs include a battery in the powertrain
system that may meet the IRA battery tax credit requirements if the applicable criteria are met.
The battery tax credits begin to phase down starting in CY 2030 and expire after CY 2032.

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Table 3-5: Battery Tax Credit in Millions of 2021 dollars *

Calendar
Year

Battery Tax Credits
Proposed Option
Relative to the
Reference Case

Battery Tax Credits
Alternative Option
Relative to the
Reference Case

2027

$340

$170

2028

$560

$370

2029

$880

$590

2030

$890

$630

2031

$650

$470

2032

$380

$270

2033 and
later

PV, 3%

$3,300

$2,300

PV, 7%

$2,900

$2,000

*Values rounded to two significant digits.

3.3.3 Manufacturer RPE

The manufacturer RPE is calculated by subtracting the applicable battery tax credit in Table
3-5 from the corresponding technology package RPE from Table 3-4 and the resultant
manufacturer RPE is shown in Table 3-6 and Table 3-7 for the proposal and alternative,
respectively. Table 3-6 and Table 3-7 reflects learning effects on vehicle package RPE and
battery tax credits from CY 2027 through 2055. The sum of the vehicle package RPE and battery
tax credits for each year is shown in the manufacturer RPE column. The difference in
manufacturer RPE between the proposal and reference case is presented in Table 3-6. The
difference in manufacturer RPE between the alternative and reference case is presented in Table
3-7.

Table 3-6: Total Vehicle Package RPE, Battery Tax Credits, and Manufacturer RPE (including Battery Tax
Credits) for the Proposed Option Relative to the Reference Case, All Regulatory Classes and All Fuels,

Millions of 2021 dollars*

Calendar
Year

Package
RPE

Battery Tax
Credits

Manufacturer
RPE

2027

$2,000

-$340

$1,600

2028

$1,800

-$560

$1,200

2029

$1,700

-$880

$820

2030

$2,000

-$890

$1,100

2031

$2,300

-$650

$1,700

2032

$2,000

-$380

$1,700

2033

$1,500

2034

$1,300

2035

$1,000

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Calendar
Year

Package
RPE

Battery Tax
Credits

Manufacturer
RPE

2036

$750

2037

$620

2038

$410

2039

$220

2040

$140

2041

-$40

2042

-$200

2043

-$360

2044

-$410

2045

-$550

2046

-$690

2047

-$820

2048

-$850

2049

-$970

2050

-$1,100

2051

-$1,100

2052

-$1,200

2053

-$1,300

2054

-$1,400

2055

-$1,500

PV, 3%

$9,000

-$3,300

$5,700

PV, 7%

$10,000

-$2,900

$7,100

* Negative values denote lower costs, i.e., savings in expenditures.

Table 3-7: Total Package RPE, Battery Tax Credits, and Manufacturer RPE (including Battery Tax Credits)
for the Alternative Option Relative to the Reference Case, All Regulatory Classes and All Fuels, Millions of

2021 dollars*

Calendar
Year

Package
RPE

Battery Tax
Credits

Manufacturer
RPE

2027

$920

-$170

$740

2028

$1,100

-$370

$700

2029

$1,000

-$590

$400

2030

$1,400

-$630

$740

2031

$1,400

-$470

$950

2032

$1,400

-$270

$1,100

2033

$960

2034

$810

2035

$620

2036

$440

2037

$350

2038

$200

2039

$70

2040

$8.50

2041

-$120

2042

-$230

2043

-$340

2044

-$370

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Calendar
Year

Package
RPE

Battery Tax
Credits

Manufacturer
RPE

2045

-$480

2046

-$570

2047

-$670

2048

-$680

2049

-$770

2050

-$850

2051

-$860

2052

-$940

2053

-$1,000

2054

-$1,100

2055

-$1,200

PV, 3%

$4,000

-$2,300

$1,800

PV, 7%

$5,400

-$2,000

$3,400

* Negative values denote lower costs, i.e., savings in expenditures.

3.4 Purchaser Costs

3.4.1 Purchaser RPE

The purchaser RPE is the estimated upfront vehicle cost paid by the purchaser prior to
considering the IRA vehicle tax credit. Note, as explained above in Chapter 3.3.2, we do
consider the IRA battery tax credit in estimating the manufacturer RPE, which in this analysis we
then consider to be equivalent to the purchaser RPE because we assume pass through of the IRA
battery tax credit from the manufacturer to the purchaser. In other words, in this analysis, the
manufacturer RPE and purchaser RPE are equivalent terms. The purchaser RPEs reflect the same
values as the corresponding manufacturer RPEs presented in Chapter 3.3.3.

3.4.2 Vehicle Purchase Tax Credits

Table 3-8 shows the annual estimated vehicle tax credit for BEV and FCEV vehicles from
IRA section 13403, "Qualified Commercial Clean Vehicles," for the proposal relative to the
reference case, in 2021 dollars for the proposal and alternative relative to the reference case.
These estimates were based on the detailed discussion in DRIA Chapter 2 of how we considered
vehicle tax credits. The vehicle tax credits carry through to MY 2032 with the value diminishing
over time as vehicle costs decrease due to the learning effect as shown in DRIA Chapter 2.
Beginning in CY 2033, the tax credit program expires.

Table 3-8: Vehicle Tax Credit in Millions 2021 dollars*

Calendar Year

Vehicle Tax Credit
for the Proposed Option
Relative to the
Reference Case

Vehicle Tax Credit
for the Alternative Option
Relative to the
Reference Case

2027

$810

$420

2028

$670

$420

2029

$630

$390

2030

$1,100

$820

2031

$1,600

$1,100

2032

$1,900

$1,300

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2033 and later

PV, 3%

$5,900

$3,900

PV, 7%

$5,000

$3,400

*Values rounded to two significant digits

3.4.3 Electric Vehicle Supply Equipment Costs

EVSE and associated costs are described in Chapter 2.6. EVSE is needed for charging of
BEVs and is not needed for FCEVs.lx The EVSE cost estimates are assumed to include both
direct and indirect costs and are sometimes referred to in this proposal as EVSE RPE costs. For
these EVSE cost estimates, we assume that up to two vehicles can share one DCFC port if there
is sufficient dwell time for both vehicles to meet their daily charging needs.x While fleet owners
may also choose to share Level 2 chargers across vehicles, we are conservatively assigning one
Level 2 charger per vehicle. As discussed in the DRIA, we assume that EVSE costs are incurred
by purchasers, i.e. heavy-duty vehicle pur chaser s/owners. We analyzed EVSE costs in 2021
dollars on a fleet-wide basis for this analysis. The fleet-wide annual costs associated with EVSE
for each MOVES source type and regulatory class are shown in Table 3-9 for both the proposed
and alternative options relative to the reference case.

Table 3-9: EVSE Costs, Millions 2021 dollars *

Calendar Year

EVSE Costs for

the Proposed
Option Relative
to the Reference
Case

EVSE Costs for
the Alternative
Option Relative to
the Reference
Case

2027

$1,300

$710

2028

$1,600

$1,100

2029

$1,900

$1,300

2030

$2,000

$1,500

2031

$2,200

$1,700

2032

$2,600

$1,900

2033

$2,600

$1,800

2034

$2,600

$1,800

2035

$2,500

$1,700

2036

$2,500

$1,700

2037

$2,500

$1,700

2038

$2,500

$1,700

2039

$2,600

$1,800

2040

$2,600

$1,800

2041

$2,600

$1,800

K As discussed in DRIA Chapter 2.5, rather than focusing on depot hydrogen fueling infrastructure costs that would
be incurred upfront, we included FCEV infrastructure costs in our per-kilogram retail price of hydrogen. Retail price
of hydrogen is the total price of hydrogen when it becomes available to the end user, including the costs of
production, distribution, storage, and dispensing at a fueling station. This approach is consistent with the method we
use in HD TRUCS for comparable ICE vehicles, where the equivalent diesel fuel costs are included in the diesel fuel
price instead of accounting for the costs of fuel stations separately.

x We note that for some of the vehicle types we evaluated, more than two vehicles could share a DCFC port and still
meet their daily electricity consumption needs. However, we are choosing to limit DCFC sharing to two vehicles per
EVSE port pending market developments and more robust dwell time estimates.

285

-------
Calendar Year

EVSE Costs for

the Proposed
Option Relative
to the Reference
Case

EVSE Costs for
the Alternative
Option Relative to
the Reference
Case

2042

$2,600

$1,800

2043

$2,700

$1,800

2044

$2,700

$1,900

2045

$2,700

$1,900

2046

$2,700

$1,900

2047

$2,700

$1,900

2048

$2,700

$1,900

2049

$2,800

$1,900

2050

$2,800

$1,900

2051

$2,800

$2,000

2052

$2,900

$2,000

2053

$2,900

$2,000

2054

$2,900

$2,000

2055

$2,900

$2,100

PV, 3%

$47,000

$33,000

PV, 7%

$29,000

$20,000

*Values rounded to two significant digits

3.4.4 Purchaser Upfront Vehicle Costs

The expected upfront incremental costs to the purchaser include the purchaser RPE discussed
in Chapter 3.4.1 plus the EVSE RPE in Chapter 3.4.3 less the vehicle tax credit discussed in
Chapter 3.4.2. Table 3-10 shows the estimated incremental upfront purchaser costs for BEVs and
FCEVs by calendar year for the proposed option relative to the reference case. Table 3-11 shows
the estimated incremental upfront purchaser costs for BEVs and FCEVs by calendar year for the
alternative option relative to the reference case. Note that EVSE costs are associated with BEVs
only; FCEVs do not have any associated EVSE costs.

Table 3-10: Incremental Purchaser Upfront Costs for the Proposed Option Relative to the Reference Case for

in Millions 2021 dollars*

Vehicle

Calendar

Purchase

Total Upfront

Year

Tax

jLVSjL i-OStS

Purchaser Cost

Credit

2027

$1,600

-$810

$1,300

$2,200

2028

$1,200

-$670

$1,600

$2,100

2029

$820

-$630

$1,900

$2,100

2030

$1,100

-$1,100

$2,000

$2,100

2031

$1,700

-$1,600

$2,200

$2,300

2032

$1,700

-$1,900

$2,600

$2,400

2033

$1,500

$2,600

$4,100

2034

$1,300

$2,600

$3,800

2035

$1,000

$2,500

$3,500

286

-------
Calendar
Year

Purchaser RPE

Vehicle
Purchase
Tax
Credit

EVSE Costs

Total Upfront
Purchaser Cost

2036

$750

$2,500

$3,200

2037

$620

$2,500

$3,100

2038

$410

$2,500

$3,000

2039

$220

$2,600

$2,800

2040

$140

$2,600

$2,700

2041

-$40

$2,600

2042

-$200

$2,600

$2,400

2043

-$360

$2,700

$2,300

2044

-$410

$2,700

$2,300

2045

-$550

$2,700

$2,100

2046

-$690

$2,700

$2,000

2047

-$820

$2,700

$1,900

2048

-$850

$2,700

$1,900

2049

-$970

$2,800

$1,800

2050

-$1,100

$2,800

$1,700

2051

-$1,100

$2,800

$1,700

2052

-$1,200

$2,900

$1,700

2053

-$1,300

$2,900

$1,600

2054

-$1,400

$2,900

$1,500

2055

-$1,500

$2,900

$1,400

PV, 3%

$5,700

-$5,900

$47,000

PV, 7%

$7,100

-$5,000

$29,000

$31,000

*Values rounded to two significant digits; negative values denote lower costs, i.e., savings in
expenditures.

Table 3-11: Incremental Purchaser Upfront Costs for the Alternative Option Relative to the Reference Case

for in Millions 2021 dollars*

Calendar
Year

Purchaser RPE

Vehicle
Purchase
Tax
Credit

EVSE Costs

Total Upfront
Purchaser Cost

2027

$740

-$420

$710

$1,000

2028

$700

-$420

$1,100

$1,300

2029

$400

-$390

$1,300

2030

$740

-$820

$1,500

$1,400

2031

$950

-$1,100

$1,700

$1,500

2032

$1,100

-$1,300

$1,900

$1,600

2033

$960

$1,800

$2,800

2034

$810

$1,800

$2,600

2035

$620

$1,700

$2,300

2036

$440

$1,700

$2,100

2037

$350

$1,700

$2,100

2038

$200

$1,700

$2,000

2039

$70

$1,800

2040

$1,800

2041

-$120

$1,800

$1,700

287

-------
Calendar
Year

Purchaser RPE

Vehicle
Purchase
Tax
Credit

EVSE Costs

Total Upfront
Purchaser Cost

2042

-$230

$1,800

$1,600

2043

-$340

$1,800

$1,500

2044

-$370

$1,900

$1,500

2045

-$480

$1,900

$1,400

2046

-$570

$1,900

$1,300

2047

-$670

$1,900

$1,200

2048

-$680

$1,900

$1,200

2049

-$770

$1,900

$1,100

2050

-$850

$1,900

$1,100

2051

-$860

$2,000

$1,100

2052

-$940

$2,000

$1,000

2053

-$1,000

$2,000

$990

2054

-$1,100

$2,000

$940

2055

-$1,200

$2,100

$880

PV, 3%

$1,800

-$3,900

$33,000

$30,000

PV, 7%

$3,400

-$3,400

$20,000

*Values rounded to two significant digits; negative values denote lower costs, i.e., savings in

expenditures.

3.4.5 Operating Costs

We have estimated three types of operating costs associated with the proposed HD Phase 3
CO2 emission standards and our potential projected technology pathway to comply with those
proposed standards that includes BEV or FCEV powertrains. These three types of operating costs
include decreased fuel costs of BEVs compared to comparable ICE vehicles, avoided diesel
exhaust fluid (DEF) consumption by BEVs and FCEV compared to comparable diesel-fueled
ICE vehicles, and reduced maintenance and repair costs of BEVs and FCEVs as compared to
comparable ICE vehicles. To estimate each of these costs, the results of MOVES runs, as
discussed in DRIA Chapter 4, were used to estimate costs associated with fuel consumption,
DEF consumption, and VMT. We have estimated the net effect on fuel costs, DEF costs, and
maintenance and repair costs. We describe our approach below.

3.4.5.1 Costs Associated with Fuel Usage

To determine the total costs associated with fuel usage for MY 2027 ICE vehicles, the fuel
consumption for each MOVES source type/regulatory class/fuel type combination was
multiplied by the fuel price from the AEO 2022 reference case for diesel, gasoline, or CNG
prices over the lifetime of the vehicle.10 We used retail fuel prices since we expect that retail fuel
prices are the prices paid by owners of these ICE vehicles. For electric vehicle costs, the
electricity price from the AEO 2022 reference case for commercial electricity end-use prices in
cents per kWh was multiplied by the fuel usage in kWh, as described in Chapter 2.4.4.2.11 For
hydrogen vehicle fuel costs, we used an H2 price of $6.10/kg starting in 2027 and linearly
decreasing to $4/kg in 2030 and held constant until 2055, as discussed in Chapter 2.5.3.1, and
multiplied the prices by H2 fuel usage in kg. To calculate the average cost per mile of fuel usage

288

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for each scenario, MOVES source type/ regulatory class/fuel type combination, the fuel cost was
divided by the VMT for each of the MY 2027 vehicles over the 28-year period. The estimates of
fuel cost per mile for MY 2027 vehicles under the proposal are shown in Table 3-12 with 3
percent discounting and Table 3-13 with 7 percent discounting. Blank values in Table 3-12 and
Table 3-13 represent cases where a given MOVES source type and regulatory class did not use a
specific fuel type for MY 2027 vehicles.X1

The retail fuel cost per mile across all vehicles fuel types, as well as the change in cost
relative to the reference case for the proposed and alternative cases, are shown in Table 3-14 and
Table 3-15 for the 3-percent and 7-percent discounting cases. When considering the retail fuel
costs per vehicle between scenarios, the impacts show no impact or a cost savings for both the
proposal and alternative cases for nearly every MOVES source type and regulatory class.

Table 3-12: Retail Fuel Cost Per Mile for Model Year 2027 Vehicles During the First 28 Years for each
MOVES Source Type and Regulatory Class by Fuel Type* (cents/mile in 2021 dollars, 3% discounting)

MOVES Source Type

Regulatory Class

Diesel

Gasoline

Electricity

CNG

Hydrogen

Other Buses

LHD45

37.2

23.9

MHD67

31.3

29.5

HHD8

32.4

30.6

40.1

Transit Bus

LHD45

37.1

14.7

MHD67

31.5

18.0

Urban Bus

32.8

18.4

40.1

School Bus

LHD45

27.5

10.1

MHD67

24.4

30.4

13.1

HHD8

25.7

13.8

32.5

Refuse Truck

MHD67

33.9

43.0

22.2

HHD8

35.3

23.2

44.1

Single Unit Short-haul
Truck

LHD45

16.7

25.7

9.0

MHD67

25.3

32.5

13.7

HHD8

30.4

16.4

38.5

Single Unit Long-haul
Truck

LHD45

15.7

24.4

14.9

23.2

MHD67

23.7

30.4

22.6

35.1

HHD8

28.5

27.1

36.4

42.2

Combination Short-haul
Truck

MHD67

34.5

24.8

HHD8

36.0

25.9

42.9

Combination Long-haul
Truck

MHD67

33.0

47.6

HHD8

33.6

39.4

48.5

* Values rounded to the nearest tenth of a cent; Blank values represent cases where a given MOVES source type
and regulatory class did not use a specific fuel type.

X1 For example, there were no vehicles in our MOVES runs for the transit bus source type in the LHD45 regulatory
class that are diesel-fueled, so the value in the table is left blank.

289

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Table 3-13: Retail Fuel Cost Per Mile for Model Year 2027 Vehicles During the First 28 Years for each
MOVES Source Type and Regulatory Class by Fuel Type* (cents/mile in 2021 dollars, 7% discounting)

MOVES Source Type

Regulatory Class

Diesel

Gasoline

Electricity

CNG

Hydrogen

Other Buses

LHD45

26.3

16.9

MHD67

22.1

20.9

HHD8

22.9

21.7

28.3

Transit Bus

LHD45

26.5

10.6

MHD67

22.6

12.9

Urban Bus

23.5

13.2

28.6

School Bus

LHD45

19.4

7.2

MHD67

17.3

21.4

9.3

HHD8

18.2

9.8

22.9

Refuse Truck

MHD67

24.9

31.4

16.3

HHD8

25.9

17.0

32.2

Single Unit Short-haul
Truck

LHD45

12.8

19.6

6.9

MHD67

19.4

24.8

10.5

HHD8

23.3

12.6

29.3

Single Unit Long-haul
Truck

LHD45

12.2

18.9

11.6

18.3

MHD67

18.4

23.6

17.5

27.8

HHD8

22.1

21.0

28.2

33.3

Combination Short-haul
Truck

MHD67

27.0

19.4

HHD8

28.2

20.2

33.5

Combination Long-haul
Truck

MHD67

24.8

36.4

HHD8

25.3

29.6

37.1

* Values rounded to the nearest tenth of a cent; Blank values represent cases where a given MOVES source type
and regulatory class did not use a specific fuel type.

Table 3-14: Retail Fuel Cost Per Mile for Model Year 2027 Vehicles During the First 28 Years for each
MOVES Source Type and Regulatory Class Across All Fuel Types*

(cents/mile in 2021 dollars, 3% discounting)

290

-------
MOVES
Source Type

Regulatory
Class

Cost in
Reference

Cost in
Proposal

Cost in
Alternative

Proposal
Change from
Reference

Alternative
Change from
Reference

Other Buses

LHD45

36.8

29.9

34.2

-6.9

-2.5

MHD67

31.2

31.0

31.1

-0.2

HHD8

33.2

0.0

Transit Bus

LHD45

36.3

29.9

32.1

-6.4

-4.2

MHD67

31.0

30.7

30.9

-0.3

-0.1

Urban Bus

33.2

0.0

School Bus

LHD45

26.9

24.3

25.3

-2.5

-1.6

MHD67

24.5

21.1

22.3

-3.4

-2.2

HHD8

26.4

24.4

25.1

-1.9

-1.2

Refuse Truck

MHD67

33.5

0.0

HHD8

35.9

34.0

34.7

-1.9

-1.2

Single Unit
Short-haul
Truck

LHD45

20.6

18.8

19.4

-1.8

-1.2

MHD67

26.1

24.4

25.0

-1.8

-1.1

HHD8

30.4

28.0

28.9

-2.5

-1.6

Single Unit
Long-haul
Truck

LHD45

19.9

19.2

19.5

-0.7

-0.4

MHD67

25.2

25.0

25.1

-0.2

-0.1

HHD8

29.4

29.2

29.3

-0.2

-0.1

Combination
Short-haul
Truck

MHD67

34.4

33.6

34.1

-0.7

-0.3

HHD8

35.9

35.0

35.5

-0.8

-0.3

Combination
Long-haul
Truck

MHD67

33.2

0.0

HHD8

33.9

0.0

* Values rounded to the nearest tenth of a cent; Negative values denote lower costs, i.e., savings in expenditures.

291

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Table 3-15: Retail Fuel Cost Per Mile for Model Year 2027 Vehicles During the First 28 Years for each
MOVES Source Type and Regulatory Class Across All Fuel Types*

(cents/mile in 2021 dollars, 7% discounting)

MOVES
Source Type

Regulatory
Class

Cost in
Reference

Cost in
Proposal

Cost in
Alternative

Proposal
Change from
Reference

Alternative
Change from
Reference

Other Buses

LHD45

26.0

21.1

24.2

-4.8

-1.8

MHD67

22.1

21.9

22.0

-0.2

-0.1

HHD8

23.5

0.0

Transit Bus

LHD45

26.0

21.4

22.9

-4.6

-3.0

MHD67

22.2

22.0

22.2

-0.2

-0.1

Urban Bus

23.8

0.0

School Bus

LHD45

19.0

17.2

17.8

-1.8

-1.1

MHD67

17.3

14.9

15.8

-2.4

-1.6

HHD8

18.6

17.3

17.8

-1.4

-0.9

Refuse Truck

MHD67

24.6

0.0

HHD8

26.3

24.9

25.4

-1.4

-0.9

Single Unit
Short-haul
Truck

LHD45

15.7

14.3

14.8

-1.4

-0.9

MHD67

20.0

18.6

19.1

-1.4

-0.8

HHD8

23.3

21.4

22.1

-1.9

-1.2

Single Unit
Long-haul
Truck

LHD45

15.5

14.9

15.1

-0.6

-0.3

MHD67

19.6

19.4

19.5

-0.2

-0.1

HHD8

22.9

22.7

22.8

-0.1

Combination
Short-haul
Truck

MHD67

26.9

26.3

26.6

-0.6

-0.2

HHD8

28.1

27.4

27.8

-0.7

-0.3

Combination
Long-haul
Truck

MHD67

25.0

0.0

HHD8

25.5

0.0

* Values rounded to the nearest tenth of a cent; Negative values denote lower costs, i.e., savings in expenditures.

Table 3-16 and Table 3-17 present the annual undiscounted fuel costs associated with the
proposal and alternative, respectively. CNG fuel savings are calculated as gasoline gallon
equivalents and, as such, are monetized using gasoline fuel prices.

Table 3-16: Annual Undiscounted Pre-Tax Fuel Costs for the Proposal Relative to the Reference Case,

Millions of 2021 Dollars *

292

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Calendar Year

Diesel

Gasoline

CNG

Electricity

Hydrogen

Sum

2027

-$370

-$160

-$4

$390

-$150

2028

-$810

-$360

-$8

$840

-$340

2029

-$1,300

-$590

-$12

$1,400

-$580

2030

-$2,300

-$870

-$24

$1,900

$520

-$710

2031

-$3,800

-$1,200

-$39

$2,500

$1,700

-$710

2032

-$5,600

-$1,600

-$59

$3,200

$3,300

-$710

2033

-$7,400

-$2,100

-$78

$3,900

$4,900

-$680

2034

-$9,100

-$2,500

-$97

$4,600

$6,500

-$630

2035

-$11,000

-$2,900

-$120

$5,200

$8,100

-$610

2036

-$12,000

-$3,300

-$130

$5,700

$9,600

-$640

2037

-$14,000

-$3,800

-$150

$6,200

$11,000

-$710

2038

-$15,000

-$4,200

-$170

$6,600

$12,000

-$810

2039

-$17,000

-$4,600

-$190

$7,100

$14,000

-$780

2040

-$18,000

-$5,000

-$220

$7,500

$15,000

-$940

2041

-$19,000

-$5,400

-$240

$7,800

$16,000

-$1,100

2042

-$20,000

-$5,800

-$260

$8,200

$17,000

-$1,100

2043

-$21,000

-$6,200

-$290

$8,500

$18,000

-$1,400

2044

-$22,000

-$6,600

-$320

$8,700

$19,000

-$1,900

2045

-$23,000

-$7,000

-$350

$8,900

$19,000

-$2,200

2046

-$24,000

-$7,400

-$380

$9,200

$20,000

-$2,600

2047

-$24,000

-$7,800

-$410

$9,300

$20,000

-$2,800

2048

-$25,000

-$8,000

-$440

$9,500

$21,000

-$2,900

2049

-$25,000

-$8,400

-$480

$9,700

$21,000

-$3,000

2050

-$25,000

-$8,700

-$520

$9,800

$21,000

-$3,200

2051

-$26,000

-$9,100

-$570

$10,000

$22,000

-$3,400

2052

-$26,000

-$9,400

-$610

$10,000

$22,000

-$3,600

2053

-$26,000

-$9,700

-$670

$10,000

$22,000

-$3,800

2054

-$26,000

-$10,000

-$720

$10,000

$23,000

-$4,000

2055

-$26,000

-$10,000

-$780

$10,000

$23,000

-$4,300

* Values rounded to two significant digits; Negative values denote lower costs, i.e., savings in expenditures.

Table 3-17: Annual Undiscounted Pre-Tax Fuel Costs for the Alternative Relative to the Reference Case,

Millions of 2021 Dollars *

Calendar Year

Diesel

Gasoline

CNG

Electricity

Hydrogen

Sum

2027

-$190

-$86

-$2

$190

-$85

2028

-$480

-$220

-$5

$490

-$220

2029

-$840

-$390

-$8

$840

-$400

2030

-$1,600

-$610

-$18

$1,200

$500

-$460

2031

-$2,600

-$890

-$30

$1,700

$1,300

-$510

2032

-$3,900

-$1,200

-$44

$2,200

$2,500

-$500

2033

-$5,200

-$1,500

-$58

$2,700

$3,700

-$470

2034

-$6,500

-$1,900

-$71

$3,100

$4,900

-$410

2035

-$7,700

-$2,200

-$84

$3,500

$6,000

-$390

2036

-$8,900

-$2,500

-$97

$3,900

$7,200

-$390

2037

-$10,000

-$2,800

-$110

$4,200

$8,200

-$430

2038

-$11,000

-$3,100

-$130

$4,500

$9,300

-$470

2039

-$12,000

-$3,400

-$140

$4,800

$10,000

-$440

293

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Calendar Year

Diesel

Gasoline

CNG

Electricity

Hydrogen

Sum

2040

-$13,000

-$3,700

-$150

$5,100

$11,000

-$530

2041

-$14,000

-$4,000

-$170

$5,400

$12,000

-$620

2042

-$14,000

-$4,300

-$190

$5,600

$13,000

-$610

2043

-$15,000

-$4,600

-$210

$5,800

$13,000

-$860

2044

-$16,000

-$4,900

-$230

$5,900

$14,000

-$1,200

2045

-$16,000

-$5,100

-$250

$6,100

$14,000

-$1,300

2046

-$17,000

-$5,400

-$270

$6,300

$15,000

-$1,600

2047

-$17,000

-$5,700

-$290

$6,400

$15,000

-$1,800

2048

-$18,000

-$5,900

-$310

$6,500

$15,000

-$1,800

2049

-$18,000

-$6,100

-$340

$6,600

$16,000

-$1,900

2050

-$18,000

-$6,400

-$370

$6,700

$16,000

-$2,000

2051

-$18,000

-$6,600

-$400

$6,800

$16,000

-$2,200

2052

-$18,000

-$6,900

-$430

$6,900

$16,000

-$2,300

2053

-$19,000

-$7,100

-$470

$7,000

$17,000

-$2,500

2054

-$19,000

-$7,400

-$510

$7,100

$17,000

-$2,600

2055

-$19,000

-$7,600

-$550

$7,200

$17,000

-$2,800

* Values rounded to two significant digits; Negative values denote lower costs, i.e., savings in expenditures.

3.4.5.2 Costs Associated with Diesel Exhaust Fluid

DEF consumption costs in heavy-duty vehicles were estimated in the HD2027 final rule.12
We are applying the same methodology in this analysis to estimate the total costs of DEF under
the proposed HD Phase 3 CO2 standards. An example of total cost estimates of DEF for MY
2027 vehicles is provided in Table 3-18 and Table 3-19 for 3 percent and 7 percent discounting,
respectively. To determine the total costs associated with DEF usage for MY 2027 vehicles, the
DEF usage for each MOVES source type and regulatory class was multiplied by the DEF price
over the first 28 years of the lifetime of the vehicle.xu The total DEF cost was divided by the total
VMT for the MY 2027 vehicles (including ICE, BEV, and FCEVs) for each MOVES Source
Type and regulatory class combination over the 28-year period to determine the average cost of
DEF per mile. The DEF cost per mile was computed for the reference case, alternative case and
proposed standard. The estimates of DEF cost per mile for the reference and proposed cases are
shown in Table 3-18 for 3 percent discounting and Table 3-19 for 7 percent discounting. Several
source types and regulatory classes contain no diesel-fueled ICE vehicles in either the reference
or proposed case and therefore no DEF consumption costs. These cases are represented as zeros
in Table 3-18 and Table 3-19. Table 3-18 and Table 3-19 show a reduction or no change in DEF
costs per mile, which is to be expected due to an increased number of BEVs and FCEVs modeled
for the proposed and alternative cases compared to the reference case.

Table 3-18: DEF Cost Per Mile for Model Year 2027 Vehicles During the First 28 Years for each MOVES
Source Type and Regulatory Class Across All Fuel Types* (cents/mile in 2021 dollars, 3% discounting)

xn This analysis uses the DEF prices presented in the NCP Technical Support Document (see "Nonconformance
Penalties for On-highway Heavy-duty Diesel Engines: Technical Support Document," EPA-420-R-12-014) with
growth beyond 2042 projected at the same 1.3 percent rate as noted in the NCP TSD. Note that the DEF prices used
update the NCP TSD's 2011 prices to 2021 dollars.

294

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MOVES
Source Type

Regulatory
Class

Cost in
Reference

Cost in
Proposal

Cost in
Alternative

Proposal
Change from
Reference

Alternative
Change from
Reference

Other Buses

LHD45

0.00

MHD67

1.89

1.61

1.71

-0.29

-0.18

HHD8

1.72

0.00

Transit Bus

LHD45

0.00

MHD67

1.90

1.85

1.88

-0.05

-0.02

Urban Bus

1.74

0.00

School Bus

LHD45

0.00

MHD67

1.37

0.96

1.10

-0.40

-0.27

HHD8

1.32

1.11

1.18

-0.20

-0.13

Refuse Truck

MHD67

2.03

0.00

HHD8

1.86

1.58

1.69

-0.28

-0.18

Single Unit
Short-haul
Truck

LHD45

0.52

0.44

0.47

-0.08

-0.05

MHD67

1.24

1.07

1.13

-0.18

-0.11

HHD8

1.70

1.40

1.51

-0.30

-0.19

Single Unit
Long-haul
Truck

LHD45

0.48

0.41

0.44

-0.07

-0.05

MHD67

1.16

1.05

1.09

-0.12

-0.07

HHD8

1.59

1.43

1.49

-0.16

-0.09

Combination
Short-haul
Truck

MHD67

2.08

1.92

2.01

-0.16

-0.07

HHD8

2.17

1.98

2.09

-0.18

-0.08

Combination
Long-haul
Truck

MHD67

2.00

0.00

HHD8

2.04

0.00

*Values rounded to the nearest hundredth of a cent; negative values denote lower costs, i.e., savings in expenditures.

Table 3-19: DEF Cost Per Mile for Model Year 2027 Vehicles During the First 28 Years for each MOVES
Source Type and Regulatory Class Across All Fuel Types*

(cents/mile in 2021 dollars, 7% discounting)

MOVES
Source Type

Regulatory
Class

Cost in
Reference

Cost in
Proposal

Cost in
Alternative

Proposal
Change from
Reference

Alternative
Change from
Reference

Other Buses

LHD45

0.00

MHD67

1.32

1.12

1.20

-0.20

-0.13

HHD8

1.20

0.00

Transit Bus

LHD45

0.00

MHD67

1.34

1.31

1.33

-0.04

-0.01

Urban Bus

1.23

0.00

School Bus

LHD45

0.00

MHD67

0.95

0.67

0.77

-0.28

-0.19

HHD8

0.92

0.78

0.83

-0.14

-0.09

Refuse Truck

MHD67

1.47

0.00

HHD8

1.35

1.15

1.22

-0.20

-0.13

Single Unit
Short-haul
Truck

LHD45

0.39

0.33

0.35

-0.06

-0.04

MHD67

0.94

0.81

0.86

-0.13

-0.08

HHD8

1.29

1.06

1.15

-0.23

-0.15

LHD45

0.37

0.32

0.34

-0.06

-0.04

295

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MOVES
Source Type

Regulatory
Class

Cost in
Reference

Cost in
Proposal

Cost in
Alternative

Proposal
Change from
Reference

Alternative
Change from
Reference

Single Unit
Long-haul
Truck

MHD67

0.90

0.81

0.84

-0.09

-0.05

HHD8

1.22

1.10

1.15

-0.12

-0.07

Combination
Short-haul
Truck

MHD67

1.62

1.49

1.57

-0.12

-0.05

HHD8

1.68

1.54

1.63

-0.14

-0.06

Combination
Long-haul
Truck

MHD67

1.50

0.00

HHD8

1.52

0.00

*Values rounded to the nearest hundredth of a cent; negative values denote lower costs, i.e., savings in expenditures.

Table 3-20 and Table 3-21 show the annual savings associated with less DEF consumption in
the proposal and alternative relative to the reference case, respectively. Note that non-diesel
vehicles are shown for completeness with no savings since those vehicles do not consume DEF.

Table 3-20: Annual Undiscounted DEF Costs for the Proposal relative to the Reference Case, Millions of 2021

dollars*

Calendar Year

Diesel

Gasoline

CNG

Electricity

Hydrogen

Sum

2027

-$27

2028

-$58

2029

-$97

2030

-$160

2031

-$270

2032

-$410

2033

-$540

2034

-$680

2035

-$810

2036

-$930

2037

-$1,100

2038

-$1,200

2039

-$1,300

2040

-$1,400

2041

-$1,500

2042

-$1,600

2043

-$1,700

2044

-$1,700

2045

-$1,800

2046

-$1,900

2047

-$1,900

2048

-$2,000

2049

-$2,000

2050

-$2,100

2051

-$2,100

2052

-$2,200

2053

-$2,200

2054

-$2,300

296

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Calendar Year

Diesel

Gasoline

CNG

Electricity

Hydrogen

Sum

2055

-$2,300

* Values rounded to two significant digits; Negative values denote lower costs, i.e., savings in expenditures.

Table 3-21: Annual Undiscounted DEF Costs for the Alternative relative to the Reference Case, Millions of

2021 dollars*

Calendar Year

Diesel

Gasoline

CNG

Electricity

Hydrogen

Sum

2027

-$14

2028

-$35

2029

-$60

2030

-$110

2031

-$190

2032

-$290

2033

-$390

2034

-$480

2035

-$580

2036

-$660

2037

-$750

2038

-$830

2039

-$910

2040

-$990

2041

-$1,100

2042

-$1,100

2043

-$1,200

2044

-$1,200

2045

-$1,300

2046

-$1,300

2047

-$1,400

2048

-$1,400

2049

-$1,400

2050

-$1,500

2051

-$1,500

2052

-$1,600

2053

-$1,600

2054

-$1,600

2055

-$1,700

* Values rounded to two significant digits; Negative values denote lower costs, i.e., savings in expenditures.

3.4.5.3 Costs Associated with Maintenance and Repair

We assessed the estimated maintenance and repair costs of HD BEVs and FCEVs and
compared these estimates with estimated maintenance and repair costs for comparable HD ICE
vehicles on an annual basis. The results of our analysis show that maintenance and repair costs
associated with HD BEVs and FCEVs are estimated to be lower than maintenance and repair
costs associated with comparable ICE vehicles.

For the estimate of maintenance and repair costs for diesel-fueled ICE vehicles, we relied on
the research compiled by Burnham et al. 2021, in Chapter 3.5.5 of "Comprehensive Total Cost of
Ownership Quantification for Vehicles with Different Size Classes and Powertrains" and used

297

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equations found in the BEAN model, as discussed in DRIA Chapter 2.3.13'14 Burnham et al. used
data from Utilimarc and ATRI to estimate maintenance and repair costs per mile for multiple
heavy-duty vehicle categories over time. Equation 72 is the curve Burnham et al. used to
estimate cost per mile as a function of age and vehicle type. We selected the box truck curve to
represent vocational vehicles and short-haul tractors, and the semi-tractor curve to represent
long-haul tractors used in Burnham et al. Table 3-22 shows the slope and intercept used in
Equation 72 for each vehicle type. The values in Table 3-22 were converted to 2021 dollars. We
assumed that gasoline and CNG vehicles had the same maintenance and repair costs curves as
diesel vehicles.

As discussed in Chapter 2, Several literature sources propose multiplying diesel vehicle
maintenance costs by a factor to estimate BEV and FCEV maintenance costs. We followed this
approach and used a factor of 0.71 for BEVs and 0.75 for FCEV, based on the research in Wang
et al., 2022.15 We used the scalars listed in Table 3-23 and slope and intercept listed in Table
3-22 in Equation 72 to compute the maintenance and repair costs on a per mile basis.

Equation 72: Maintenance and repair costs dollars per mile as a function of age and vehicle type
mrage = scaler * (slope * age + intercept)

Where,

mrage represents the estimated maintenance and repair cost in dollars per mile at a given age

scaler is the value based on the vehicle type

slope is based on vehicle fuel type

age is the current age of the vehicle

intercept is based on vehicle type

Table 3-22: Values for Determining Maintenance and Repair in 2019 Dollars

Vehicle Source Type

slope

intercept

Vocational vehicles and short-haul tractors

0.09

0.2618

Long-Haul Combination Trucks

0.03

0.11

Table 3-23 Scalers of Maintenance and Repair based on Vehicle Fuel Type

Vehicle Fuel Type

scaler

Diesel

Gasoline

CNG

Electricity

0.71

Hydrogen

0.75

To determine the maintenance and repair cost for MY 2027 vehicles, Equation 72 was
computed at every age from 0 to 28 for each MOVES source type and fuel type. Then a cost for
a single age was determined by multiplying the maintenance and repair costs at that age by VMT
at that age. Then, the total maintenance and repair costs for each MOVES Source Type and
regulatory class in the reference, proposal, and alternative scenarios were calculated by summing
the cost for all years from CY 2027 (age=0) to CY 2055 (age=28). To determine the average cost
per mile for each scenario, the total maintenance and repair cost was divided by the total VMT

298

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by all MY 2027 vehicles over the 28-year period for each MOVES Source Type. For each
MOVES source type, the cost of maintenance and repair per mile remained the same regardless
of regulatory class and are reported by MOVES source type in Table 3-24 through Table 3-27.

A comparison of the maintenance and repair cost on a per mile basis for comparable ICE
vehicles compared to BEVs are shown in Table 3-24 and Table 3-25 for the discounting cases of
3 and 7 percent, respectively. The results show the reduced cost of maintenance and repair for
electric vehicles compared to diesel, gasoline, and CNG.

The impacts of maintenance and repairs for MY 2027 vehicles in each MOVES source type
associated with reference, proposed, and alterative cases are shown in Table 3-26 and Table 3-27
at 3-percent and 7-percent discounting, respectively. Both the proposed and alternative cases
show either no changexm or reductions in maintenance and repair costs when compared to the
reference case.

Table 3-24: Maintenance and Repair Per Mile for Model Year 2027 Vehicles During the First 28 Years for
Each MOVES Source Type, ICE compared to BEV and FCEV Costs* (cents/mile in 2021 dollars, 3%

discounting)

MOVES Source Type

ICE

BEV

FCEV

Other Buses

80.8

57.4

Transit Bus

79.2

56.3

School Bus

80.9

57.4

Refuse Truck

76.1

54.1

Single Unit Short-haul Truck

69.9

49.6

Single Unit Long-haul Truck

67.5

47.9

50.6

Combination Short-haul Truck

66.4

47.1

Combination Long-haul Truck

26.0

19.5

* Values rounded to the nearest tenth of a cent.; All ICE vehicles (Diesel, Gasoline
and CNG) had the same cost per mile for each source type.

Table 3-25: Maintenance and Repair Per Mile for Model Year 2027 Vehicles During the First 28 Years for
Each MOVES Source Type, ICE to BEV and FCEV * (cents/mile in 2021 dollars, 7% discounting)

MOVES Source Type

ICE

BEV

FCEV

Other Buses

49.3

35.0

Transit Bus

49.0

34.8

School Bus

49.3

35.0

Refuse Truck

49.3

35.0

Single Unit Short-haul Truck

47.9

34.0

Single Unit Long-haul Truck

47.2

35.4

Combination Short-haul Truck

47.3

33.6

Combination Long-haul Truck

17.6

13.2

xm There are no changes to vehicle populations for MY 2027 between the proposal and reference cases for the
MOVES source type of Combination Long-haul Truck, which is why the maintenance and repair cost per mile
shows no change between the proposal and reference case.

299

-------
MOVES Source Type

ICE

BEV

FCEV

*Values rounded to the nearest tenth of a cent.; All ICE vehicles (Diesel, Gasoline and CNG) had the same cost per
mile for each source type.

Table 3-26: Maintenance and Repair Per Mile for Model Year 2027 Vehicles During the First 28 Years for
Each MOVES Source Type, for all Vehicle Types* (cents/mile in 2021 dollars, 3% discounting)

MOVES Source
Type

Cost in
Reference

Cost in
Proposal

Cost in
Alternative

Proposal Change
from Reference

Alternative Change
from Reference

Other Buses

80.0

74.8

78.1

-5.2

-1.9

Transit Bus

78.4

75.6

76.6

-2.8

-1.9

School Bus

80.1

73.9

76.0

-6.2

-4.1

Refuse Truck

75.4

72.8

73.7

-2.6

-1.6

Single Unit Short-
haul Truck

69.2

66.2

67.3

-3.1

-1.9

Single Unit Long-
haul Truck

67.0

64.4

65.4

-2.5

-1.6

Combination
Short-haul Truck

66.1

64.6

65.5

-1.6

-0.6

Combination
Long-haul Truck

25.9

0.0

*Values rounded to the nearest tenth of a cent; Negative values denote lower costs, i.e., savings in expenditures.

Table 3-27: Maintenance and Repair Per Mile for Model Year 2027 Vehicles During the First 28 Years for
Each MOVES Source Type, for all Vehicle Types* (cents/mile in 2021 dollars, 7% discounting)

MOVES Source
Type

Cost in
Reference

Cost in
Proposal

Cost in
Alternative

Proposal Change
from Reference

Alternative Change
from Reference

Other Buses

48.8

45.6

47.6

-3.2

-1.2

Transit Bus

48.5

46.8

47.4

-1.7

-1.2

School Bus

48.8

45.0

46.3

-3.8

-2.5

Refuse Truck

48.8

47.1

47.7

-1.7

-1.1

Single Unit Short-
haul Truck

47.5

45.4

46.1

-2.1

-1.3

Single Unit Long-
haul Truck

46.8

45.1

45.7

-1.8

-1.1

Combination
Short-haul Truck

47.1

46.0

46.6

-1.1

-0.5

Combination
Long-haul Truck

17.5

0.0

*Values rounded to the nearest tenth of a cent; Negative values denote lower costs, i.e., savings in expenditures.

Table 3-28 and Table 3-29 present the projected total maintenance and repair costs associated
with the proposal and alternative, respectively. The total maintenance and repair costs are
attributable to changes in new vehicle sales and vehicle populations. The maintenance and repair
costs on a per vehicle basis are the same in the proposal and alternative, but as more HD ZEVs
enter the HD fleet, the total maintenance and repair costs for the fleet of those vehicles
correspondingly increases. The opposite is true for diesel, gasoline, and CNG vehicles as they

300

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phase out of the fleet such that the total maintenance and repair costs for the fleet of those
vehicles decreases as more HD ZEVs enter the HD fleet.

Table 3-28: Annual Undiscounted Total Maintenance & Repair Costs for the Proposal Relative to the

Reference Case, Millions of 2021 Dollars *

Calendar Year

Diesel
Vehicles

Gasoline
Vehicles

CNG
Vehicles

BEVs

FCEVs

Total

2027

-$370

-$150

-$3

$380

-$150

2028

-$940

-$400

-$7

$950

-$390

2029

-$1,700

-$740

-$12

$1,800

-$720

2030

-$2,900

-$1,200

-$22

$2,800

$140

-$1,200

2031

-$4,700

-$1,800

-$36

$4,100

$530

-$1,900

2032

-$7,000

-$2,600

-$56

$5,700

$1,100

-$2,700

2033

-$9,600

-$3,400

-$78

$7,500

$1,900

-$3,700

2034

-$12,000

-$4,400

-$100

$9,500

$2,700

-$4,800

2035

-$15,000

-$5,500

-$130

$11,000

$3,700

-$5,900

2036

-$19,000

-$6,700

-$160

$14,000

$4,800

-$7,100

2037

-$22,000

-$7,900

-$190

$16,000

$5,800

-$8,400

2038

-$25,000

-$9,100

-$220

$18,000

$6,900

-$9,600

2039

-$28,000

-$10,000

-$260

$20,000

$8,100

-$11,000

2040

-$31,000

-$12,000

-$300

$22,000

$9,200

-$12,000

2041

-$34,000

-$13,000

-$330

$24,000

$10,000

-$13,000

2042

-$37,000

-$14,000

-$380

$26,000

$11,000

-$14,000

2043

-$39,000

-$15,000

-$420

$27,000

$12,000

-$15,000

2044

-$41,000

-$17,000

-$460

$29,000

$13,000

-$16,000

2045

-$43,000

-$18,000

-$510

$31,000

$14,000

-$17,000

2046

-$45,000

-$19,000

-$560

$32,000

$15,000

-$18,000

2047

-$47,000

-$20,000

-$620

$34,000

$15,000

-$19,000

2048

-$48,000

-$21,000

-$670

$35,000

$16,000

-$19,000

2049

-$49,000

-$22,000

-$740

$36,000

$16,000

-$20,000

2050

-$51,000

-$24,000

-$800

$38,000

$17,000

-$21,000

2051

-$52,000

-$25,000

-$880

$39,000

$17,000

-$22,000

2052

-$53,000

-$26,000

-$960

$40,000

$17,000

-$22,000

2053

-$54,000

-$27,000

-$1,000

$42,000

$18,000

-$23,000

2054

-$55,000

-$28,000

-$1,100

$43,000

$18,000

-$24,000

2055

-$56,000

-$30,000

-$1,200

$44,000

$19,000

-$24,000

* Values rounded to two significant digits; negative values denote lower costs, i.e., savings in expenditures.

Table 3-29: Annual Undiscounted Total Maintenance & Repair Costs for the Alternative Relative to the

Reference Case, Millions of 2021 Dollars *

Calendar Year

Diesel
Vehicles

Gasoline
Vehicles

CNG
Vehicles

BEVs

FCEVs

Total

2027

-$200

-$86

-$2

$200

-$83

2028

-$570

-$250

-$4

$580

-$240

2029

-$1,100

-$500

-$8

$1,100

-$470

2030

-$2,000

-$840

-$16

$1,900

$130

-$820

2031

-$3,200

-$1,300

-$27

$2,900

$410

-$1,300

301

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Calendar Year

Diesel
Vehicles

Gasoline
Vehicles

CNG
Vehicles

BEVs

FCEVs

Total

2032

-$4,900

-$1,900

-$41

$4,000

$850

-$1,900

2033

-$6,700

-$2,600

-$57

$5,300

$1,400

-$2,600

2034

-$8,800

-$3,300

-$75

$6,700

$2,000

-$3,400

2035

-$11,000

-$4,100

-$95

$8,200

$2,700

-$4,300

2036

-$13,000

-$5,000

-$120

$9,700

$3,500

-$5,100

2037

-$16,000

-$5,900

-$140

$11,000

$4,300

-$6,000

2038

-$18,000

-$6,800

-$160

$13,000

$5,100

-$6,900

2039

-$20,000

-$7,700

-$190

$14,000

$5,900

-$7,800

2040

-$22,000

-$8,700

-$210

$16,000

$6,700

-$8,600

2041

-$24,000

-$9,600

-$240

$17,000

$7,500

-$9,500

2042

-$26,000

-$11,000

-$270

$18,000

$8,300

-$10,000

2043

-$28,000

-$11,000

-$300

$20,000

$9,000

-$11,000

2044

-$29,000

-$12,000

-$330

$21,000

$9,600

-$12,000

2045

-$31,000

-$13,000

-$360

$22,000

$10,000

-$12,000

2046

-$32,000

-$14,000

-$400

$23,000

$11,000

-$13,000

2047

-$33,000

-$15,000

-$440

$24,000

$11,000

-$13,000

2048

-$34,000

-$16,000

-$480

$25,000

$11,000

-$14,000

2049

-$35,000

-$16,000

-$520

$26,000

$12,000

-$14,000

2050

-$36,000

-$17,000

-$570

$27,000

$12,000

-$15,000

2051

-$37,000

-$18,000

-$620

$28,000

$13,000

-$15,000

2052

-$38,000

-$19,000

-$680

$29,000

$13,000

-$16,000

2053

-$38,000

-$20,000

-$730

$30,000

$13,000

-$16,000

2054

-$39,000

-$21,000

-$800

$31,000

$13,000

-$17,000

2055

-$40,000

-$22,000

-$870

$31,000

$14,000

-$17,000

* Values rounded to two significant digits; negative values denote lower costs, i.e., savings in expenditures.

3.4.6 Analysis of Payback Periods

A payback period is the point in time at which savings from reduced operating expenses
surpass increased upfront costs, typically estimated in years. The payback period for a new
vehicle purchase is an important metric for many HD vehicle purchasers. In general, there is
greater willingness to pay for new technology if that new technology "pays back" within an
acceptable period of time. A payback period is calculated in DRIA Chapter 2.8.2 using HD
TRUCS for specific use cases and average payback periods are calculated in DRIA Chapter 2.9.4
by regulatory groups. Briefly, the incremental upfront costs for ZEVs are estimated in contrast to
comparable ICE vehicles. In these incremental upfront costs for ZEVs, IRA battery and vehicle
tax credits factored in as discussed in DRIA Chapter 3.3.2 and 3.4.2. Then the expected
operating costs differences between ZEV and ICE vehicles are computed over a 10-year
assessment period. When the 10-year average operating cost savings offset the incremental
upfront differences between ZEV and ICE vehicles, a breakeven point is met. The amount of
time from purchase to the breakeven point is defined as the payback period.

3.5 Social Costs

To compute the social costs of the proposal, alternative and reference scenarios, we added the
estimated total vehicle technology package RPE from Section 3.2.3, operating costs from
Chapter 3.4.5, and total EVSE RPE from Chapter 3.4.3. We note that the fuel costs in this

302

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subsection's social cost analysis are estimated pre-tax rather than what the purchaser would pay
(i.e., the retail fuel price). All of the costs are computed for the MOVES proposed, alternative
and reference cases and cost impacts are presented as the difference between the proposed and
reference case or alternative and reference case. Additionally, the battery tax credit and the
vehicle tax credit, like fuel taxes, are treated as transfers and are not included in our social costs.
We present transfers in Chapter 8.2 of this DRIA.

3.5.1 Total Vehicle Technology Package RPE

Table 3-30 and Table 3-31 show the direct manufacturing costs, indirect costs, and total
technology costs of the proposed and alternative options relative to the reference case. Values
shown for a given calendar year are undiscounted values while discounted values are presented
at both 3-percent and 7-percent discount rates. All values are shown in 2021 dollars.

Table 3-30: Total Package RPE Cost Impacts of the Proposed Option Relative to the Reference Case, All
Regulatory Classes and All Fuels, Millions of 2021 Dollars*

Calendar Year

Direct Manufacturing Costs

Indirect Costs

Total Technology Package Costs

2027

$1,400

$590

$2,000

2028

$1,200

$520

$1,800

2029

$1,200

$500

$1,700

2030

$1,400

$590

$2,000

2031

$1,600

$680

$2,300

2032

$1,400

$600

$2,000

2033

$1,100

$440

$1,500

2034

$900

$380

$1,300

2035

$710

$300

$1,000

2036

$530

$220

$750

2037

$440

$180

$620

2038

$290

$120

$410

2039

$160

$66

$220

2040

$95

$40

$140

2041

-$29

-$12

-$40

2042

-$140

-$60

-$200

2043

-$250

-$110

-$360

2044

-$290

-$120

-$410

2045

-$390

-$160

-$550

2046

-$490

-$200

-$690

2047

-$580

-$240

-$820

2048

-$600

-$250

-$850

2049

-$680

-$290

-$970

2050

-$760

-$320

-$1,100

2051

-$770

-$320

-$1,100

2052

-$850

-$360

-$1,200

2053

-$930

-$390

-$1,300

2054

-$1,000

-$420

-$1,400

2055

-$1,100

-$450

-$1,500

PV, 3%

$6,300

$2,700

$9,000

PV, 7%

$7,100

$3,000

$10,000

* Values show 2 significant digits; negative values denote lower costs, i.e., savings in expenditures.

303

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Table 3-31: Total Package RPE Cost Impacts of the Alternative Option Relative to the Reference Case, All
Regulatory Classes and All Fuels, Millions of 2021 Dollars*

Calendar Year

Direct Manufacturing Costs

Indirect Costs

Total Technology Package Costs

2027

$650

$270

$920

2028

$760

$320

$1,100

2029

$700

$300

$1,000

2030

$970

$410

$1,400

2031

$1,000

$420

$1,400

2032

$950

$400

$1,400

2033

$680

$280

$960

2034

$570

$240

$810

2035

$430

$180

$620

2036

$310

$130

$440

2037

$250

$100

$350

2038

$140

$60

$200

2039

$49

$21

$70

2040

$2.50

$8.50

2041

-$81

-$34

-$120

2042

-$160

-$68

-$230

2043

-$240

-$100

-$340

2044

-$260

-$110

-$370

2045

-$330

-$140

-$480

2046

-$400

-$170

-$570

2047

-$470

-$200

-$670

2048

-$480

-$200

-$680

2049

-$540

-$230

-$770

2050

-$600

-$250

-$850

2051

-$610

-$250

-$860

2052

-$660

-$280

-$940

2053

-$720

-$300

-$1,000

2054

-$770

-$320

-$1,100

2055

-$820

-$350

-$1,200

PV, 3%

$2,800

$1,200

$4,000

PV, 7%

$3,800

$1,600

$5,400

* Values show 2 significant digits; negative values denote lower costs, i.e., savings in expenditures.

3.5.2 Total EVSE RPE

Table 3-32 shows the EVSE cost in the reference, proposal and alternative cases, as well as
the differences between the proposal and reference cases and the difference between the
alternative and reference cases. Values shown for a given calendar year are undiscounted values
while discounted values are presented at both 3-percent and 7-percent discount rates. All values
are shown in 2021 dollars.

Table 3-32: Total ESVE Cost in the Reference, Proposed, Alternative, Change between Proposed and
Reference Case, Change between Alternative and Reference Case; All Regulatory Classes and All Fuels,

Millions of 2021 Dollars*

Calendar
Year

Cost in
Reference

Cost in
Proposal

Cost in
Alternative

Proposal Change
from Reference

Alternative Change
from Reference

2027

$370

$1,700

$1,100

$1,300

$710

2028

$530

$2,100

$1,600

$1,100

304

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Calendar
Year

Cost in
Reference

Cost in
Proposal

Cost in
Alternative

Proposal Change
from Reference

Alternative Change
from Reference

2029

$720

$2,600

$2,000

$1,900

$1,300

2030

$910

$2,900

$2,400

$2,000

$1,500

2031

$1,000

$3,200

$2,700

$2,200

$1,700

2032

$1,200

$3,800

$3,000

$2,600

$1,900

2033

$1,200

$3,800

$3,100

$2,600

$1,800

2034

$1,300

$3,900

$3,100

$2,600

$1,800

2035

$1,400

$3,900

$3,100

$2,500

$1,700

2036

$1,400

$3,900

$3,100

$2,500

$1,700

2037

$1,400

$4,000

$3,200

$2,500

$1,700

2038

$1,500

$4,000

$3,200

$2,500

$1,700

2039

$1,500

$4,000

$3,200

$2,600

$1,800

2040

$1,500

$4,100

$3,300

$2,600

$1,800

2041

$1,500

$4,100

$3,300

$2,600

$1,800

2042

$1,500

$4,200

$3,300

$2,600

$1,800

2043

$1,500

$4,200

$3,400

$2,700

$1,800

2044

$1,500

$4,200

$3,400

$2,700

$1,900

2045

$1,500

$4,200

$3,400

$2,700

$1,900

2046

$1,600

$4,300

$3,500

$2,700

$1,900

2047

$1,600

$4,300

$3,500

$2,700

$1,900

2048

$1,600

$4,300

$3,500

$2,700

$1,900

2049

$1,600

$4,300

$3,500

$2,800

$1,900

2050

$1,600

$4,400

$3,600

$2,800

$1,900

2051

$1,600

$4,500

$3,600

$2,800

$2,000

2052

$1,700

$4,500

$3,600

$2,900

$2,000

2053

$1,700

$4,600

$3,700

$2,900

$2,000

2054

$1,700

$4,600

$3,700

$2,900

$2,000

2055

$1,700

$4,700

$3,800

$2,900

$2,100

PV, 3%

$25,000

$72,000

$58,000

$47,000

$33,000

PV, 7%

$15,000

$44,000

$35,000

$29,000

$20,000

* Values show 2 significant digits; negative values denote lower costs, i.e., savings in expenditures.

3.5.3 Total Operating Cost

Table 3-33 and Table 3-34 show the total operating costs of the proposed and alternative
options relative to the reference case. Each table shows the operating costs for pre-tax fuel costs,
DEF costs, maintenance and repair costs, and the net operating cost. Values shown for a given
calendar year are undiscounted values while discounted values are presented at both 3-percent
and 7-percent discount rates. All values are shown in 2021 dollars.

Note that the fuel costs, DEF costs, and maintenance costs are shown as negative costs, or
savings. This is expected as these costs are lower for electric vehicles and the proposal and
alternative options include a greater number of electric vehicles than the reference case.

Table 3-33: Total Operating Cost Impacts of the Proposed Option Relative to the Reference Case, All
Regulatory Classes and All Fuels, Millions of 2021 Dollars*

Calendar Year

Pre-Tax Fuel Costs

DEF Costs

Maintenance Costs

Total Operating Costs

2027

-$150

-$27

-$150

-$330

2028

-$340

-$58

-$390

-$790

2029

-$580

-$97

-$720

-$1,400

2030

-$710

-$160

-$1,200

-$2,100

305

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Calendar Year

Pre-Tax Fuel Costs

DEF Costs

Maintenance Costs

Total Operating Costs

2031

-$710

-$270

-$1,900

-$2,800

2032

-$710

-$410

-$2,700

-$3,800

2033

-$680

-$540

-$3,700

-$4,900

2034

-$630

-$680

-$4,800

-$6,100

2035

-$610

-$810

-$5,900

-$7,400

2036

-$640

-$930

-$7,100

-$8,700

2037

-$710

-$1,100

-$8,400

-$10,000

2038

-$810

-$1,200

-$9,600

-$12,000

2039

-$780

-$1,300

-$11,000

-$13,000

2040

-$940

-$1,400

-$12,000

-$14,000

2041

-$1,100

-$1,500

-$13,000

-$16,000

2042

-$1,100

-$1,600

-$14,000

-$17,000

2043

-$1,400

-$1,700

-$15,000

-$18,000

2044

-$1,900

-$1,700

-$16,000

-$20,000

2045

-$2,200

-$1,800

-$17,000

-$21,000

2046

-$2,600

-$1,900

-$18,000

-$22,000

2047

-$2,800

-$1,900

-$19,000

-$23,000

2048

-$2,900

-$2,000

-$19,000

-$24,000

2049

-$3,000

-$2,000

-$20,000

-$25,000

2050

-$3,200

-$2,100

-$21,000

-$26,000

2051

-$3,400

-$2,100

-$22,000

-$27,000

2052

-$3,600

-$2,200

-$22,000

-$28,000

2053

-$3,800

-$2,200

-$23,000

-$29,000

2054

-$4,000

-$2,300

-$24,000

-$30,000

2055

-$4,300

-$2,300

-$24,000

-$31,000

PV, 3%

-$28,000

-$22,000

-$200,000

-$250,000

PV, 7%

-$14,000

-$11,000

-$99,000

-$120,000

* Values show 2 significant digits; negative values denote lower costs, i.e., savings in expenditures.

Table 3-34: Total Operating Cost Impacts of the Alternative Option Relative to the Reference Case, All
Regulatory Classes and All Fuels, Millions of 2021 Dollars*

Calendar Year

Pre-Tax Fuel Costs

DEF Costs

Maintenance Costs

Total Operating Costs

2027

-$85

-$14

-$83

-$180

2028

-$220

-$35

-$240

-$490

2029

-$400

-$60

-$470

-$920

2030

-$460

-$110

-$820

-$1,400

2031

-$510

-$190

-$1,300

-$2,000

2032

-$500

-$290

-$1,900

-$2,700

2033

-$470

-$390

-$2,600

-$3,500

2034

-$410

-$480

-$3,400

-$4,300

2035

-$390

-$580

-$4,300

-$5,200

2036

-$390

-$660

-$5,100

-$6,200

2037

-$430

-$750

-$6,000

-$7,200

2038

-$470

-$830

-$6,900

-$8,200

2039

-$440

-$910

-$7,800

-$9,100

2040

-$530

-$990

-$8,600

-$10,000

2041

-$620

-$1,100

-$9,500

-$11,000

2042

-$610

-$1,100

-$10,000

-$12,000

2043

-$860

-$1,200

-$11,000

-$13,000

2044

-$1,200

-$12,000

-$14,000

2045

-$1,300

-$12,000

-$15,000

306

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Calendar Year

Pre-Tax Fuel Costs

DEF Costs

Maintenance Costs

Total Operating Costs

2046

-$1,600

-$1,300

-$13,000

-$16,000

2047

-$1,800

-$1,400

-$13,000

-$17,000

2048

-$1,800

-$1,400

-$14,000

-$17,000

2049

-$1,900

-$1,400

-$14,000

-$18,000

2050

-$2,000

-$1,500

-$15,000

-$18,000

2051

-$2,200

-$1,500

-$15,000

-$19,000

2052

-$2,300

-$1,600

-$16,000

-$20,000

2053

-$2,500

-$1,600

-$16,000

-$21,000

2054

-$2,600

-$1,600

-$17,000

-$21,000

2055

-$2,800

-$1,700

-$17,000

-$22,000

PV, 3%

-$18,000

-$15,000

-$140,000

-$180,000

PV, 7%

-$8,900

-$7,900

-$71,000

-$87,000

* Values show 2 significant digits; negative values denote lower costs, i.e., savings in expenditures.

3.5.4 Total Social Cost

Using the cost elements outlined in Chapters 3.2.3, 3.4.3, and 3.4.5, we have estimated the
costs associated with the proposal; costs associated with the proposal and alternative relative to
the reference case are shown in Table 3-35 and Table 3-36, respectively. As noted earlier, costs
are presented in 2021 dollars in undiscounted annual values along with net present values at both
3-percent and 7-percent discount rates with values discounted to the 2027 calendar year.

As shown in these tables, our analysis shows that the proposal scenario would have the lowest
costs, followed by the alternative and reference scenarios, respectively.

Table 3-35: Total Technology, Operating Cost and EVSE Cost Impacts of the Proposed Option Relative to
the Reference Case, All Regulatory Classes and All Fuels, Millions of 2021 dollars*

Total

Calendar Year

Technology
Package Costs

Total Operating Costs

Total EVSE Costs

Sum

2027

$2,000

-$330

$1,300

$3,000

2028

$1,800

-$790

$1,600

$2,500

2029

$1,700

-$1,400

$1,900

$2,200

2030

$2,000

-$2,100

$2,000

$1,900

2031

$2,300

-$2,800

$2,200

$1,700

2032

$2,000

-$3,800

$2,600

$860

2033

$1,500

-$4,900

$2,600

-$820

2034

$1,300

-$6,100

$2,600

-$2,200

2035

$1,000

-$7,400

$2,500

-$3,800

2036

$750

-$8,700

$2,500

-$5,500

2037

$620

-$10,000

$2,500

-$7,000

2038

$410

-$12,000

$2,500

-$8,700

2039

$220

-$13,000

$2,600

-$10,000

2040

$140

-$14,000

$2,600

-$12,000

2041

-$40

-$16,000

$2,600

-$13,000

2042

-$200

-$17,000

$2,600

-$15,000

2043

-$360

-$18,000

$2,700

-$16,000

2044

-$410

-$20,000

$2,700

-$18,000

307

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Calendar Year

Total
Technology
Package Costs

Total Operating Costs

Total EVSE Costs

Sum

2045

-$550

-$21,000

$2,700

-$19,000

2046

-$690

-$22,000

$2,700

-$20,000

2047

-$820

-$23,000

$2,700

-$22,000

2048

-$850

-$24,000

$2,700

-$22,000

2049

-$970

-$25,000

$2,800

-$23,000

2050

-$1,100

-$26,000

$2,800

-$24,000

2051

-$1,100

-$27,000

$2,800

-$25,000

2052

-$1,200

-$28,000

$2,900

-$26,000

2053

-$1,300

-$29,000

$2,900

-$27,000

2054

-$1,400

-$30,000

$2,900

-$28,000

2055

-$1,500

-$31,000

$2,900

-$29,000

PV, 3%

$9,000

-$250,000

$47,000

-$190,000

PV, 7%

$10,000

-$120,000

$29,000

-$85,000

Annualized, 3%

$470

-$13,000

$2,500

-$10,000

Annualized, 7%

$820

-$10,000

$2,300

-$6,900

* Values show 2 significant digits; negative values denote lower costs, i.e., savings in

expenditures.

Table 3-36: Total Technology, Operating Cost and EVSE Cost Impacts of the Alternative Option Relative to
the Reference Case, All Regulatory Classes and All Fuels, Millions of 2021 dollars*

Total

Calendar Year

Technology

Total Operating Costs

Total EVSE Costs

Sum

Package Costs

2027

$920

-$180

$710

$1,400

2028

$1,100

-$490

100

$1,600

2029

$1,000

-$920

300

$1,400

2030

$1,400

-$1,400

500

$1,400

2031

$1,400

-$2,000

700

$1,100

2032

$1,400

-$2,700

900

$510

2033

$960

-$3,500

800

-$710

2034

$810

-$4,300

800

-$1,700

2035

$620

-$5,200

700

-$2,900

2036

$440

-$6,200

700

-$4,000

2037

$350

-$7,200

700

-$5,100

2038

$200

-$8,200

700

-$6,300

2039

$70

-$9,100

800

-$7,300

2040

-$10,000

800

-$8,400

2041

-$120

-$11,000

800

-$9,400

2042

-$230

-$12,000

800

-$10,000

2043

-$340

-$13,000

800

-$12,000

2044

-$370

-$14,000

900

-$13,000

2045

-$480

-$15,000

900

-$13,000

2046

-$570

-$16,000

900

-$14,000

2047

-$670

-$17,000

900

-$15,000

2048

-$680

-$17,000

900

-$16,000

2049

-$770

-$18,000

900

-$17,000

308

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Total

Calendar Year

Technology
Package Costs

Total Operating Costs

Total EVSE Costs

Sum

2050

-$850

-$18,000

$1,900

-$17,000

2051

-$860

-$19,000

$2,000

-$18,000

2052

-$940

-$20,000

$2,000

-$19,000

2053

-$1,000

-$21,000

$2,000

-$20,000

2054

-$1,100

-$21,000

$2,000

-$20,000

2055

-$1,200

-$22,000

$2,100

-$21,000

PV, 3%

$4,000

-$180,000

$33,000

-$140,000

PV, 7%

$5,400

-$87,000

$20,000

-$62,000

Annualized, 3%

$210

-$9,100

$1,700

-$7,200

Annualized, 7%

$440

-$7,100

$1,600

-$5,100

* Values show 2 significant digits; negative values denote lower costs, i.e., savings in
expenditures.

Chapter 3 References

1 See Advisory Circular A-4, Office of Management and Budget, September 17, 2003.

2 See Advisory Circular A-4, Office of Management and Budget, September 17, 2003.

3 See Python tool, Docket ID No. EPA-HQ-OAR-2022-0985.

4 "Cost Reduction through Learning in Manufacturing Industries and in the Manufacture of Mobile Sources, Final
Report and Peer Review Report," EPA-420-R-16-018, November 2016.

5 See the 2011 heavy-duty greenhouse gas rule (76 FR 57106, September 15, 2011); the 2016 heavy-duty
greenhouse gas rule (81 FR 73478, October 25, 2016).

6 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

7 See 75 FR 25324, 76 FR 57106, 77 FR 62624, 79 FR 23414, 81 FR 73478, 86 FR 74434.

8 Heavy Duty Truck Retail Price Equivalent and Indirect Cost Multipliers, Draft Report, RTI International, RTI
Project Number 021 1577.003.002, July 2010.

9 Rogozhin, Alex, Michael Gallaher, Gloria Helfand, and Walter McManus. "Using Indirect Cost Multipliers to
Estimate the Total Cost of Adding New Technology in the Automobile Industry." International Journal of
Production Economics 124 (2010): 360-368.

10 Reference Case Projection Tables, U.S. Energy Information Administration. Annual Energy Outlook 2022.

11 U.S. Energy Information Administration. Annual Energy Outlook 2022.

12 88 FR 4296, Januaiy 24, 2023.

13Burnham, A., Gohlke, D., Rush, L., Stephens, T., Zhou, Y., Delucchi, M. A., Birky, A., Hunter, C., Lin, Z., Ou, S.,
Xie, F., Proctor, C., Wiryadinata, S., Liu, N, Boloor, M. "Comprehensive Total Cost of Ownership Quantification
for Vehicles with Different Size Classes and Powertrains". Argonne National Laboratory. Chapter 3.5.5. April 1,
2021. Available at https://publications.anl.gov/anlpubs/2021/05/167399.pdf.

14 Argonne National Lab, Vehicle & Mobility Systems Group, BEAN, found at: https://vms.taps.anl. gov/tools/bean/
(accessed August 2022).

15 Wang, G., Miller, M., and Fulton, L." Estimating Maintenance and Repair Costs for Battery Electric and Fuel Cell
Heavy Duty Trucks, 2022. Available online:

https://escholarship.org/content/qt36c08395/qt36c08395_noSplash_589098e470b036b3010eae00f3b7b618.pdf?t=r6
zwjb.

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Chapter 4 Emission Inventories

4.1 Introduction

This chapter presents our analysis of the national emissions impacts of the proposal and
alternative (collectively referred to as control cases) for calendar years 2027 through 2055 from
both downstream and some upstream sources. Downstream emissions are those emitted directly
by a vehicle, including tailpipe and crankcase exhaust (from running, starts, or extended idle),
evaporative emissions, refueling emissions, and particulate emissions from brake wear and tire
wear. Upstream emissions are not emitted by the vehicle itself but can still be attributed to its
operation. Examples include emissions from electricity generation for charging battery electric
vehicles, the creation of hydrogen fuel for fuel cell electric vehicles, the extracting and refining
of crude, and the transporting of crude or refined fuels for internal combustion vehicles.

We estimated onroad downstream national inventories using an updated version of EPA's
Motor Vehicle Emission Simulator (MOVES) model. The version of MOVES used for the
emissions inventory modeling, called MOVES3.R3,1 includes several updates from MOVES3.1,2
the latest widely available public version. The onroad national emission inventories were
developed using a single national modeling domain (which includes the 50 U.S. states and the
District of Columbia, but not any U.S. territories), referred to as national or default scale in
MOVES.

This chapter also presents our analysis of the national emissions impacts of the proposal and
alternative for some upstream emissions sources, including emissions from electricity generation
units (EGUs) that result from increased energy demand from heavy-duty electric vehicles. EGU
emissions were modeled using the Integrated Planning Model (IPM). IPM is a linear
programming model that accounts for variables and information such as energy demand, planned
EGU retirements, and planned rules to forecast EGU-level energy production and configurations.
More details on IPM and the specific version used in this proposal can be found online3 or in the
docket4.

In addition, this chapter presents our estimates of the proposal and alternative's impacts on
refinery emissions. This analysis uses adjustments to the 2050 inventory based on some
assumptions about how refinery activity will change in response to lower demand for liquid fuel.

All our modeling is done for a full national domain, so all emissions impacts cover the full
national inventory. Emissions impacts in other domains, such as particular regions or localities in
the United States, are likely to differ from the impacts presented in this chapter.

Chapter 4.2 describes the updates to MOVES to model the proposed standards in detail.
Chapter 4.3 describes the downstream and upstream emissions modeling inputs and methodology
we used to model the proposed CO2 emission standards. Emission inventory impacts of the
proposal are discussed in Chapters 4.4 (downstream emissions), 4.5 (upstream emissions), and
4.6 (net emissions impacts). Finally, Chapter 4.7 compares emission inventory impacts of the
proposal and alternative.

4.2 Model Data and Updates

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To quantify the emissions impacts of the proposal and alternative, EPA developed an updated
version of MOVES, called MOVES3.R3. It includes significant algorithm and data updates from
MOVES3.1, especially related to the modeling of electric vehicles. MOVES3.R3 also
incorporates the HD2027 final rule, as described more in detail in Chapter 4.2.1.3. Detailed
descriptions of the underlying data and analyses that informed the model updates are
documented in technical reports included in the docket. In addition, MOVES3.R3 and its
supporting database can be found in the docket.1

MOVES defines vehicles using a combination of source type and regulatory class, where
source type roughly defines a vehicle's vocation or usage pattern, and regulatory class defines a
vehicle's gross vehicle weight rating (GVWR) or weight class. Table 4-1 defines MOVES source
types and Table 4-2 defines MOVES regulatory classes.

Table 4-1 MOVES source type definitions

sourceTypelD

Source Type Description

Motorcycle

Passenger Car

Passenger Truck

Light Commercial Truck

Other Bus

Transit Bus

School Bus

Refuse Truck

Single Unit Short-haul Truck

Single Unit Long-haul Truck

Motor Home

Combination Short-haul Truck

Combination Long-haul Truck

Table 4-2 MOVES regulatory class definitions

regClassID

Regulatory Class Name

Regulatory Class Description and GVWR Range

Motorcycle

LDV

Light Duty Vehicles

LDT

Light Duty Trucks

LHD2B3

Chassis-certified Class 2b and 3 Trucks
8,500 lbs < GVWR < 14,000 lbs

LHD45

Class 4 and 5 Trucks and engine-certified Class 3 Trucks
14,000 lbs < GVWR < 19,500 lbs

MHD67

Class 6 and 7 Trucks
19,500 lbs < GVWR < 33,000 lbs

HHD8

Class 8a and 8b Trucks
GVWR > 33,000 lbs

Urban Bus

Urban Bus (see CFR Sec 86.091 2)5

Gliders

Glider Vehicles (see EPA-420-F-15-904)6

4.2.1 Model Updates in MOVES3.R3

MOVES3.R3 incorporates the latest vehicle activity data, newer emission rules, and changes
that reflect improvements in our understanding of vehicle emissions. It also adds features to

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better model zero-emission vehicles (ZEVs), such as battery electric vehicles (BEVs) and fuel
cell electric vehicles (FCEVs). In addition to the HD-related updates described below,
MOVES3.R3 includes updates to light-duty vehicles that are kept the same between the
reference and the control scenarios, discussed in Appendix A to Chapter 4- Updates to
MOVES3.R3 for light-duty vehicles.

Many of the updates discussed in this chapter and in Appendix 4. A were made for a
preliminary version of MOVES that we developed between MOVES3 and MOVES3.R3. This
version of MOVES has been independently peer-reviewed, including the most significant
updates for the modeling of HD ZEVs (Chapter 4.2.1.1), combination long-haul tractors fueled
by compressed natural gas (CNG) or fuel cells (Chapter 4.2.1.2), heavy-duty ICE vehicles
(Chapter 4.2.1.3), and vehicle population and activity updates (Chapter 4.2.1.4).

4.2.1.1 HD ZEV energy consumption

In developing the HD ZEV energy consumption rates, we used the Energy Efficiency Ratio
(EER) of BEVs to diesel vehicles. The energy consumption of a HD BEV can be calculated
using diesel energy consumption and the EER as shown in Equation 4-1. EERs were calculated
for each source type based on a literature review. Data in each study was mapped to a MOVES
source type, and each source type's EER was calculated as the unweighted average of all
published EERs. Details on the literature review studies and methodology may be found in the
MOVES3.R3 GHG and Energy Consumption technical report.7 While an EER can be formulated
relative to any ICE vehicle, we use diesel as the reference point because it is the dominant fuel
type in the HD fleet.

Equation 4-1 Calculation of HD BEV energy consumption rates using Energy Efficiency Ratio (EER)

Energydiesei

EnergyBEV =

EER

The EER for a BEV is generally greater than 1, indicating that BEVs are more efficient than
their diesel counterparts. For example, an EER of 2 means a BEV is twice as efficient as its
diesel counterpart and, therefore, consumes half the energy consumed by a comparable diesel
vehicle. Table 4-3 shows the EER calculated for each HD source type.

Table 4-3 MOVES3.R3 Energy Efficiency Ratios for Heavy-duty Electric Vehicles

sourceTypelD

Source Type Description

Average EER

Other Buses

2.0

Transit Buses

3.3

School Buses

3.5

Refuse Trucks

2.9

Single Unit Short-Haul Trucks

3.5

Single Unit Long-Haul Trucks

2.0

Motor Homes

2.0

Combination Short-Haul Trucks

2.6

Combination Long-Haul Trucks

2.0

For BEVs, energy consumption is calculated by first duplicating diesel energy consumption
rates for all electric vehicles, and then applying the EER. After the base rates are calculated,

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MOVES applies two adjustments to model real-world energy consumption. The first is a
temperature adjustment, which captures use of heating, ventilation, and air conditioning
(HVAC). The second is an adjustment based on charging and battery efficiency, to reflect the
true grid demand of BEVs.

Temperature adjustments in MOVES3.R3 were added for BEVs and FCEVs. The primary
data sources for the ZEV temperature adjustments are (1) an American Automobile Association
(AAA) study8 which tested several BEV passenger cars on a chassis dynamometer at room
temperature, low temperature (20°F), and high temperature (95°F), and (2) a real-world study of
temperature effects on BEV and FCEV buses.9

To account for the total demand BEVs have on the grid, BEV charging and battery efficiency
were introduced and implemented in MOVES3.R3, applied with the temperature adjustment to
the base energy rates. In MOVES3.R3, charging efficiency captures the energy lost in the
charging equipment - essentially the ratio of the energy added to the battery and the energy
drawn from the power grid. Battery efficiency, meanwhile, captures the relative energy lost in
the battery itself due to internal resistance - the ratio of the energy added to the battery and the
energy produced at the output terminal.

The charging efficiency and battery efficiency values in MOVES3.R3 are based on a
literature review documented in the MOVES3.R3 Onroad Emission Adjustments report.10 The
charging and battery efficiency values by age group used in MOVES3.R3 are in Table 4-4.
MOVES3.R3 uses the same charging and battery efficiency assumptions for all BEVs, regardless
of vehicle class and model year, due to a lack of more specific data.

Table 4-4 EV Charging and Battery Efficiency Assumptions in MOVES3.R3

Age Group

Battery Efficiency

Charging Efficiency

0-3 years

0.95

0.94

4-5 years

0.903153

0.94

6-7 years

0.874407

0.94

8-9 years

0.847435

0.94

10-14 years

0.828273

0.94

15-20 years

0.828273

0.94

20+ years

0.828273

0.94

The EER approach described for BEVs, and the base rate adjustments, also applies to FCEVs
in MOVES3.R3. Similar to BEVs, the base energy consumption rates for FCEVs are duplicated
from diesel. However, based on analysis done to compare the energy efficiency between BEVs
and FCEVs, the base energy consumption rates for FCEVs are scaled up from those of BEVs by
a factor of 1.25 to reflect the lower FCEV efficiency. The scaling factor is based on values from
a 2022 study on alternative fuel efficiency in HD vehicles by Islam, Vijayagopal, and
Rousseau,11 and is consistent with Argonne National Laboratory's Greenhouse Gases, Regulated
Emissions, and Energy Use in Transportation (GREET) 2022 model. 12The adjustment ensures
the final energy consumption rates for FCEVs are representative of their real-world operation
and is further documented in the MOVES3.R3 GHG and Energy Consumption report.7.

4.2.1.2 CNG and FCEV Combination Long-Haul Tractors

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MOVES3.R3 includes new capabilities to model combination long-haul trucks (source type
62) with fuel types other than diesel, adding compressed natural gas (CNG) and electricity.
Electric combination long-haul trucks can be either BEVs or FCEVs. This required a significant
update to the hotelling1 and extended idle emissions and activity algorithms. However, these
updates did not affect diesel hotelling or extended idle emission rates or the diesel hotelling
activity distribution.

The modeling of CNG combination long-haul tractors requires the addition of base extended
idle rates for CNG tractors. There was no data available directly measuring extended idle
emissions from CNG tractors, so we copied CNG running idle rates (operating mode 1 of the
running process in MOVES) for extended idle rates. Extended idle rates for diesel tractors are
significantly higher than running idle rates because emission controls are highly dependent on
exhaust temperature,13'14 but emission controls on CNG vehicles are not as sensitive to exhaust
temperature. Therefore, running idle emission rates can serve as a good proxy for extended idle
CNG rates when there is a lack of directly measured data.

MOVES3.R3 introduces a new hotelling process called shore power, where some long-haul
tractors do not use any systems on the vehicles itself while hotelling and plug into power at a
facility instead. Since shore power is the dominant power source for hotelling ZEVs, and since it
is important to capture the effect that ZEVs have on the energy grid, MOVES3.R3 models
energy consumption from shore power.

Shore power energy consumption is calculated based on the ratio of grid energy consumption
to diesel auxiliary power unit (APU) energy consumption. MOVES3.R3 uses a factor of 1/8,
based on a study published by Frey and Kuo in 200915 which measures energy consumption for
diesel engines, diesel APUs, and shore power. There is little data directly measuring shore power
and APU energy consumption, so we use this study because it provides a direct comparison
between two which is suitable for calculating an energy consumption ratio.

In MOVES, the hotelling activity distribution defines the percentage of hotelling time for
which a tractor is extended idling, using an APU, using shore power, or has all systems off. We
did not find any data on the hotelling activity distribution of CNG or ZEV tractors, so their
distributions are based on the distribution for diesel combination long-haul tractors. We made
changes to the distribution based on the assumption that neither CNG nor ZEV tractors are sold
with diesel APUs. Therefore, we assume, in our modeling, CNG and ZEV tractors would use
shore power, replacing all extended idle and APU activity.

All other hoteling and extended idle algorithms, data, and base rates for diesel combination
long-haul tractors remain unchanged in MOVES3.R3. Hotelling activity is further documented in
the MOVES3.R3 Vehicle Population and Activity technical report,16 while hoteling emission
rates are further documented in the MOVES3.R3 Heavy-Duty Exhaust Emissions technical
report.17

4.2.1.3 Updates for heavy-duty ICE vehicles

1 Hotelling is time spent by long-haul truck drivers in the tractor when it is parked during mandatory rest periods,
such as overnight at truck stops. Hotelling applies only to long-haul combination trucks, not vocational vehicles.
While hotelling, many vehicle accessories, such as HVAC, are engaged and powered using the tractor's engine or
some other power source. When accessories are powered using the engine, this is called extended idle.

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There were several updates to MOVES3.R3 made to improve modeling of emissions from
HD ICE vehicles. Details on all changes to HD ICE vehicles may be found in the MOVES3.R3
Heavy-Duty Exhaust Emissions technical report.17

The most significant updates to HD vehicle emissions in MOVES3.R3 are those implemented
to model the HD2027 standards finalized in December 2022.18 The rule begins in MY 2027 and
has several program areas, which we included in MOVES in four steps.11 First, consistent with
the HD2027 standards, MOVES3.R3 has significantly reduced base exhaust emission rates of
nitrogen oxides (NOx), carbon monoxide (CO), total hydrocarbons, and particulate matter (PM)
for MY 2027 and later HD vehicles for running, starts, and extended idle. Second, crankcase
exhaust emissions of many criteria pollutants and air toxics are reduced due to closed crankcase
provisions in the rule. Third, we updated the deterioration of HD emission rates to be consistent
with the extended useful life and warranty periods defined in the rule. Finally, refueling
emissions of hydrocarbons, including volatile organic compounds and air toxics, from HD
gasoline vehicles are significantly reduced due to increased adoption of onboard refueling vapor
recovery (ORVR) technology.

HD ICE ammonia emission rates were updated for MOVES3.R3, based on measurements
collected at the Caldecott Tunnel near Oakland, California by Preble et al in 2019.19 We also
updated the crankcase to tailpipe ratios for MY 2007 and later vehicles, using newly collected
data, such as Khalek et al. (2009)20 and testing done at the EPA National Vehicle and Fuel
Emissions Laboratory (NVFEL) in 2015 and 2018. HD nitrous oxide (N2O) rates were updated
and substantially increased for MY 2010 and later HD diesel vehicles with selective catalytic
reduction (SCR) emissions control systems, based largely on the Preble et al. study,19 which
shows a substantial increase in fuel-specific N2O rates for MY 2010 and later engines. In
general, these updates result in increased emissions estimates of both ammonia and N2O from
HD diesel vehicles by 50% or more in future years.

MOVES3.R3 also includes updated fuel properties for default fuel formulations. Specifically,
fuel energy content, carbon content, and sulfur content were updated based on properties
measured in batches of certification fuel. MOVES uses these fuel properties to calculate
emissions of carbon dioxide and sulfur dioxide based on total energy consumption. This update
affects emissions from all ICE onroad vehicles.

Finally, MOVES3.R3 shifts engine-certified Class 3 vehicles from the LHD2b3 regulatory
class to the MHD45 regulatory class to allow for better alignment with the underlying data.

4.2.1.4 Vehicle population and activity data

MOVES population and activity data are based on a number of sources, including the Energy
Information Administration's (EIA) Annual Energy Outlook (AEO), Federal Highway Safety
Administration's Highway Statistics, the Transportation Energy Data Book published by Oak

11 Because the HD2027 rule was not yet finalized at the time of the emissions inventory analysis performed for this
proposed rulemaking, the updates we made in MOVES3.R3 to incorporate the HD2027 standards differ slightly
from the final HD2027 program (e.g., FTP standards for MHD, off-cycle standards for MHD and HHD, and the
warranty period of HHD). We expect these differences to have negligible impact on GHGs and only a very small
impact on the overall HD NOx inventory.

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Ridge National Laboratory, the School Bus Fleet Fact Book, and vehicle registration data from
MS Markit.

MOVES3.R3 uses updated versions of these data sources, including AEO 2022,21 Highway
Statistics 2020,22 Transportation Energy Data Book Edition 40 (2022),23 the School Bus Fleet
Fact Book 2021,24 and IHS2020.25 More detail on how each source is used in MOVES can be
found in the MOVES3.R3 vehicle population and activity technical report.16

In addition, updates have been made for Class 2b and 3 (2b3) vehicles and electric vehicles
for MOVES3.R3. Light-duty (LD) BEV populations are discussed in Appendix 4.A and heavy-
duty (HD) ZEV populations are discussed in Chapters 4.3.1 and 4.3.2.

4.3 Model Inputs and Methodology

We used MOVES3.R3 to estimate the downstream emission impacts of the proposal and the
alternative. First, we estimated emissions for a baseline scenario that represents the U.S. without
the proposed rulemaking. This is called the reference case. Then, we estimated emissions for the
proposed standards and separately estimated emissions for the alternative (collectively referred
to as control cases). We calculated the emission reductions of both GHGs and non-GHGs for the
proposed standards as the difference between the emissions estimated in the reference case and
the proposal case. We also calculated the difference between the reference case and the
alternative using the same methodology. All model inputs, MOVES runspec files, scripts used
for the analysis, and the version of MOVES used to generate the emissions inventories, may be
found in the docket.26

The reference case was run entirely using MOVES3 ,R3 defaults, including HD ZEV
populations, as described in Chapter 4.3.1. These inputs are also described in detail in the
MOVES3.R3 technical reports available in the docket. The only change made to MOVES3.R3
for the purposes of modeling the proposed standards and the alternative were HD ZEV
populations. All other activity inputs, including total VMT by source type, age distributions, road
type distributions, vehicle speeds, off-network idling, hotelling, and starts were kept the same
between the reference and the control cases. Emission rates and adjustments were kept the same
as well, including energy consumption rates for all fuel types. Finally, geographic fuels inputs
were kept the same for the reference and control cases.

As discussed in Chapter 4.1, we used IPM to estimate the EGU emission impacts from the
proposed CO2 emission standards and alternative. However, we were not able to perform IPM
runs for scenarios that directly correlate to the reference, proposal, and alternative. Instead, our
methodology uses output from three IPM runs covering two scenarios. There are substantial
differences between the IPM scenarios that we modeled and the scenarios we model for
downstream emissions. Chapter 4.3.3 contains detailed discussion of how we generated IPM
inputs from MOVES and how we accounted for differences between the IPM scenarios we
modeled and the control cases for this rulemaking.

Refineries are another upstream emissions source that we expect would be impacted by
increased adoption of HD ZEVs. We conducted an exploratory analysis that provides some
insight into potential emissions impacts from this sector. The exploratory analysis is based on
emissions inventories for the year 2055 and a limited set of criteria pollutants. We were not able

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to quantify impacts from refineries on greenhouse gas emissions or in any year-over-year
inventory analysis.

4.3.1 MOVES Inputs for the Reference Case

In modeling future HD ZEV populations in the reference case, which is a scenario that
reflects expected ZEV populations absent our proposed emission standards, we considered
several different factors. First, the HD market has evolved such that early HD ZEV models are in
use today for some applications and HD ZEVs are expected to expand to many more
applications. Additionally, manufacturers have announced plans to rapidly increase their
investments in ZEV technologies over the next decade. Second, the IRA and the BIL provide
many monetary incentives for the production and purchase of ZEVs in the HD market, as well as
incentives for electric vehicle charging infrastructure. Third, there have been multiple actions by
states to accelerate the adoption of HD ZEVs, such as (1) a multi-state Memorandum of
Understanding for the support of HD ZEV adoption; and (2) the State of California's ACT
program, which has also been adopted by other states, and includes a manufacturer requirement
for zero-emission truck sales, as shown in Table 4-5.m'lv

To estimate the adoption of HD ZEVs in the reference case, we assumed a national level of
ZEV sales based on volumes expected from ACT in California and the other states that have
adopted ACT. We used those volumes as the numeric basis for a projection of the number of
ZEVs nationwide in the 2024 and later timeframe. While EPA only recently granted the ACT
rule waiver requested by California under CAA section 209(b) on March 30, 2023, we expect the
market, at a national level, was already responding to the requirements that ACT would impose,
in addition to the market responding to the market forces discussed in Section I.C of the
preamble. Because the ACT waiver was only recently granted, for this proposal EPA used the
ZEV sales volumes projections that could be expected from ACT in the reference case as an
overall projection for national ZEV sales volumes, as we made this projection prior to the
granting of the ACT waiver. We may revisit this assumption in the final rulemaking in light of
the recent granting of the ACT waiver.

Table 4-5 ZEV sales percentage schedule in California's ACT rule

Model Year

Class 4-8 Group3

Class 7-8 Tractors Group

2024

2025

11%

2026

13%

10%

2027

20%

15%

111 EPA granted the ACT rule waiver requested by California under CAA section 209(b) on March 30, 2023. Oregon
adopted ACT on 11/17/2021: https://www.oregon.gov/deq/rulemaking/Pages/ctr2021.aspx. Washington adopted
ACT on 11/29/2021: https://ecology.wa.gov/Regulations-Permits/Laws-rules-rulemaking/Rulemaking/WAC-l 73-
423-400. New York adopted ACT on 12/29/2021: https://www.dec.ny.gov/regulations/26402.html. New Jersey
adopted ACT on 12/20/2021: https://www.nj.gov/dep/rules/adoptions.html. Massachusetts adopted ACT on
12/30/2021: https://www.mass.gov/regulationsZ310-CMR-700-air-pollution-control#proposed-amendments-public-
comment.Oregon and Washington adopted ACT as-is, whereas New York, New Jersey, and Massachusetts adopted
ACT on a one-year delay.

lv In December 2022, Vermont also adopted ACT under CAA section 177 effective beginning with MY 2026. Due
to timing, it is not included in the analysis for our proposal, but Vermont's adoption of ACT further supports the
reasonableness of the ZEV level assumptions in our no action baseline. See

https://dec.vermont.gov/sites/dec/files/aqc/laws-regs/documents/Chapter_40_LEV_ZEV_rule_adopted.pdf

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2028

30%

20%

2029

40%

25%

2030

50%

30%

2031

55%

35%

2032

60%

40%

2033

65%

40%

2034

70%

40%

2035 and beyond

75%

40%

a The ACT rule includes ZEV adoption rates for a Class 2b-3 Vocational Vehicle Group,
which we also included in our reference case modeling. We did not model the proposal as
increasing ZEV adoption in this vehicle category so they are not presented here. Class 2b-3
Vocational Vehicle Group ZEV adoption rates can be found in Appendix 4A.

For the purposes of simulating the level of ZEV sales in the ACT program nationally in
MOVES, several simplifying assumptions were made. First, we assume MOVES source types 41
through 54 follow the Class 4-8 Group and source types 61 and 62 follow the Class 7-8 Tractors
Group. Second, we assume the proportion of national HD sales in the states that adopted the
ACT program remains the same as they were for MYs 2019 and 2020.v And third, we assume
HD manufacturers sell proportions of ZEVs mandated by ACT without using the flexibilities
afforded by ACT such as credit banking, weight class modifiers, or the use of near-zero
emissions vehicles, which is consistent with our approach to modeling our own regulations.

ZEV adoption is calculated as the product of the proportion of national HD vehicle sales that
belong to states that have adopted ACT and the ZEV sales percentages required by ACT. All
ZEV sales are assumed to be BEVs, except for long-haul single-unit and combination trucks
(source types 53 and 61), which are assumed to be FCEVs. We could find no data that suggests
ZEV adoption will preferentially displace ICE vehicles of any particular fuel type. While we
increased the HD ZEV adoption in MOVES, we maintained the current relative fuel distribution
between diesel, gasoline, and CNG heavy-duty vehicles into the future.

Overall, Table 4-6 shows the national adoption of HD ZEVs by source type in the reference
case.

Table 4-6 National heavy-duty ZEV adoption in the reference case

Model Year

Class 4-8 Group

Class 7-8 Tractors Group

Source Types 41-54

Source Types 61, 62

2024

1.1%

0.3%

2025

2.0%

0.7%

2026

2.4%

1.0%

2027

3.4%

1.4%

2028

5.1%

1.9%

2029

7.1%

2.5%

2030

9.1%

3.0%

2031

10.5%

3.5%

2032

11.4%

4.1%

2033

12.4%

4.3%

v We based the proportion of national HD sales in the states that have adopted ACT on vehicle registration data in
IHS2020. We used MY 2020 registrations because it was the most recent MY data available. However, the data set
encompassed a partial year of registrations, so we also included MY 2019 registrations.

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2034

13.4%

4.3%

2035

14.4%

4.3%

2036 and beyond

14.8%

4.3%

The geographic distribution of HD ZEVs is assumed to be uniform throughout the United
States, in recognition of the tendency for HD vehicles to cross state lines in operation and to
migrate across state lines over time.

4.3.2 MOVES Inputs for the Proposal and Alternative

Future HD ZEV populations in MOVES for the proposal and alternative scenarios were
estimated using HD TRUCS based on the technology assessment for BEVs and FCEVs
discussed in Chapter 2.

The ZEV adoption rate for the proposed CO2 emission standards was calculated for each of
the 101 Vehicle IDs in HD TRUCS in MY 2027 and MY 2032 as shown in Chapter 2.8.3. ZEV
adoption was then aggregated by source type and regulatory class combination with a sales-
weighted average of Vehicle IDs in each combination to calculate MY 2027 and MY 2032 ZEV
adoption rates, then interpolated following the methodology described in Chapter 2.9.1 to
calculate MY 2028-2031 ZEV adoption rates.

To determine the phase-in the BEV adoption for short-haul tractors (source type 61), we
calculated the proportion of short-haul tractor sales we project to be BEVs in MY 2032, then
linearly interpolated the BEV adoption for MYs 2030 and 2031 from MYs 2029 and 2032. We
calculated the FCEV adoption in MYs 2030-2032 as the difference between the overall ZEV
adoption and BEV adoption.

For model years after 2032, ZEV adoption for each source type and regulatory class
combination was held constant at the MY 2032 level.

For the alternative, ZEV adoption rates for MYs 2027 and 2032 were reduced from the
adoption rates for the proposal by the ratio of alternative-to-proposal adoption rates shown in
Table 4-7. For example, the vocational source types' (41-54) ZEV adoption rates for MY 2027
were multiplied by 14/20 and those for MY 2032 were multiplied by 40/50. ZEV adoption rates
for MYs 2028-2031 were interpolated following the methodology described in Chapter 2.9.1
using these newly calculated MYs 2027 and 2032 adoption rates and the adoption rates under
Alternative Stringency in Table 4-7.

Table 4-7 Comparison in ZEV adoption rates between the proposed standards and alternative

MY 2027

MY 2028

MY 2029

MY 2030

MY 2031

MY 2032
and later

Proposed Stringency

Vocational

20%

25%

30%

35%

40%

50%

Short-Haul Tractors

10%

12%

15%

20%

30%

35%

Long-Haul Tractors

10%

20%

25%

Alternative Stringency

Vocational

14%

20%

25%

30%

35%

40%

Short-Haul Tractors

10%

15%

20%

25%

Long-Haul Tractors

10%

15%

20%

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There are some combinations of source type, regulatory class, and model year for which the
BEV or FCEV adoption rates in our proposal and alternative control cases are less than the BEV
or FCEV adoption rate in the reference case. For example, reference case BEV adoption rates for
motor homes (source type 54) are greater than zero for MY 2024 and later as a result of our
simplifying assumptions described in Chapter 4.3.1, but our technology assessment described in
Chapter 2 shows no BEV adoption for this source type. In instances such as these, the BEV or
FCEV adoption rate was adjusted to be equal to the BEV or FCEV adoption rate in the reference
case; the adjusted BEV or FCEV adoption rate for all combinations of source type, regulatory
class, and model year is the greater of (A) the reference case BEV or FCEV adoption rate or (B)
the control case BEV or FCEV adoption rate.

In the reference case, we modeled long-haul HD ZEVs (source types 53 and 62) as FCEVs
and the remainder of HD ZEVs as BEVs. However, as discussed in Chapter 2, our technology
assessment used to determine the proposed standards relies on BEV technology for most
combinations of source type and regulatory class and FCEV technology for certain applications
(some vehicle types in source type/regulatory class combinations 41/47, 52/47, 61/46, 61/47, and
62/47 as shown in Chapter 2). Since any combination of ZEVs (e.g., FCEVs and BEVs) may be
used to meet our proposed standards, we assumed that any ZEVs added beyond the reference
case levels would be BEVs or FCEVs as projected in our technology package. We did not
decrease any BEV or FCEV populations from the reference case, which increase monotonically
from MY 2024 through MY 2036 (see Table 4-6). Because the proposed CO2 emission standards
reach their steady-state values before MY 2036 (i.e., by MY 2032) and because ZEV adoption
rates increase from the reference case until MY 2036, FCEV adoption rates for source
type/regulatory class combination 41/47 and BEV adoption rates for source type 53 decrease
from MY 2032 to MY 2036. This is an artifact of our assumption for the reference case that all
source type 41 ZEVs are BEVs and all 53 ZEVs are FCEVs, which does not match the
assignment of BEVs and FCEVs in our technology package.

The adjustments in the previous two paragraphs ensure higher adoption of ZEVs overall in the
control cases than the reference case. As in the reference case, each heavy-duty ZEV sale is
assumed to displace the sale of a comparable ICE vehicle, and we assume that no fuel type is
preferentially displaced. The geographic distribution of ZEVs is also assumed to be uniform
throughout the United States.

The BEV and FCEV adoption rates for the control cases by source type, regulatory class, and
model year are shown in Tables 4B-1 through 4B-9 in the Appendix 4.B.

4.3.3 Upstream Modeling

We were not able to perform IPM runs for scenarios that directly correlate to the reference
case, proposal, and alternative. Instead, our methodology uses output from three IPM runs
covering two scenarios, which we then adjusted to account for the differences between what was
modeled and the control cases in the proposal. The first two IPM runs were based on preliminary
reference and control scenarios we developed early in the regulatory development process and
that are not the same as the reference and proposal presented elsewhere in this chapter. Both
scenarios were developed before the passage of the Inflation Reduction Act (IRA),27 which we
expect to cause significant changes in emissions from EGUs. We also conducted a third run

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using the same inputs as the reference case in which IPM accounted for the portions of the IRA
with the most significant impacts on EGU emissions."

Chapter 4.3.3.1 discusses how we developed IPM inputs for each scenario and Chapter 4.3.3.2
discusses the methodology we developed to estimate EGU emissions impacts for the proposal
and alternative using the available IPM output. Chapter 4.3.3.3 discusses the methodology we
used to estimate refinery emissions impacts for calendar year 2055.

4.3.3.1 IPM Input Files

The only IPM input that we needed to update to model the preliminary reference and control
scenarios is the total electricity demand. IPM's default electricity demand is based on
AEO2021,28 which does not include the full forecasted ZEV adoption in the reference case.
Relative to AEO2021, the reference case has increased HD ZEV adoption (more details can be
found in Chapter 4.3.1) and LD BEV adoption (based on the incorporation of EPA's Revised
2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards29 into
MOVES3.R3 as discussed in Appendix 4.A). Therefore, we developed IPM input files specific
to the demand of electric vehicles not captured by IPM's defaults, which we call incremental
demand input files.

We developed a set of IPM incremental demand input files for our preliminary reference
scenario and another set for our preliminary control scenario. Electricity demand for these input
files was calculated from the output of national MOVES runs like those described in Chapters
4.1 and 4.4. The MOVES runs for the preliminary reference and control scenarios were not
performed with MOVES3.R3, but a preliminary version of MOVES. The HD ZEV energy
demand in the preliminary version of MOVES is very close (generally within 5%) to
MOVES3.R3.vii

IPM requires grid demand to be specified by day type (i.e., for an average weekday and
weekend), hour of the day, and by each of IPM's geographic regions.

We first calculated total energy demand for a typical weekend day and weekday for both
BEVs and FCEVs using MOVES output. As discussed in Chapter 4.2.1.1, MOVES energy
consumption output for BEVs represents the total grid demand related to the running and
charging of the vehicles. Therefore, the grid demand from BEVs estimated by MOVES could be
used with no further processing.

Upstream emissions that would be incurred for FCEVs due to the production of hydrogen are
not captured by MOVES. Hydrogen in the U.S. today is primarily produced via steam methane
reforming (SMR) largely as a part of petroleum refining and ammonia production. Given the BIL
and the IRA provisions that meaningfully incentivize reducing the emissions and carbon
intensity of hydrogen production, as well as new transportation and other demand drivers and

V1 We expect IRA incentives, particularly sections 45X, 45Y, and 48E of the Internal Revenue Code (i.e., Title 26)
added by sections 13502 (Advanced Manufacturing Production Credit), 13701 (Clean Electricity Production Credit),
and 13702 (Clean Electricity Investment Credit), respectively, to contribute significantly to increases in renewables
in the future power generation mix.

vn The most significant difference between the MOVES version used and MOVSE3.R3 is that the preliminary
version does not account for the finalized HD2027 standards and did not have some of the activity updates discussed
previously in Chapter 4.2. The net impact of these updates on total EV energy consumption is small, making the
output valid for developing IPM input files.

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potential future regulation, it is anticipated there will be a shift in how hydrogen is produced.
Considering this and because electrolysis is a key mature technology for hydrogen production,
our analysis includes a simplifying assumption that increased levels of hydrogen to fuel FCEVs
will be produced using grid electrolysis. Thus, all hydrogen production is represented as
additional demand to EGUs and the emissions are modeled using IPM.

We recognize that the relative emissions impact of hydrogen production via SMR versus grid
electrolysis depends on how electricity is produced, which varies significantly by region across
the country. We also recognize that electrolysis powered by electricity from the grid on average
in the U.S. may overestimate the upstream emissions impacts that are attributable to HD FCEVs
in our analysis. New electrolysis project announcements predominantly pair electrolyzers wth
zero-carbon energy sources."11 As the carbon intensity of the grid declines over time in response
to the BIL and IRA and incentives, these impacts should be mitigated.30

We developed yearly scalar multipliers which were applied to MOVES FCEV energy
consumption to represent total grid demand from the hydrogen production necessary to support
the projected levels of FCEVs. First, we assumed hydrogen is produced by a series of
decentralized, grid-powered polymer electrolyte membrane (PEM) electrolyzer systems, each
with a hydrogen production capacity around 1,500 kilograms per day.lx'31 Next, we assumed the
gaseous hydrogen is compressed and pre-cooled for delivery to vehicles using grid-powered
electrical equipment. Finally, we assumed a linear improvement between our estimated current
and future efficiency for hydrogen production. The linear interpolation is between current values
that start in 2025 and future values represented for 2055, assuming a period of diffusion for more
efficient electrolysis technology improvements to spread. The final scaling factors range from
1.748 in 2025 to 1.616 in 2055.

We allocated total daily demand of FCEVs and BEVs by the hour of day separately. FCEV
energy demand is allocated uniformly across all hours of the day because hydrogen fuel can be
produced and compressed at any time of day.

We developed charging load profiles to reflect the share of total daily demand from BEV charging that we
expect to occur each hour for both weekdays and weekends. Because vehicle use and charging patterns vary
by application, we developed individual charging profiles for seven vehicle categories: transit buses, school
buses, other buses, refuse trucks, single unit short-haul trucks, combination short-haul trucks, and motor
homes. We developed the charging profiles for HD BEVs based on soak data in MOVES.51'511'32 We used soak

times of 12 hours as a proxy for when a vehicle may be parked at a depot, warehouse, or other off-shift
location and can charge. We expect that how long a vehicle will charge and when vehicle charging begins will
vary due to different energy consumption, charging equipment, and the charging preferences of BEV owners
or operators. In developing national fleetwide charging profiles, we made the simplifying assumption that
charging demand would be evenly distributed across the last 12 hours of soak time before the vehicle starts.
Finally, the seven individual charging profiles were weighted by their share of electricity demand to calculate
overall HD BEV national charging profiles for weekdays and weekends. Because the electricity demand of

vm For electrolyzers using renewable energy, a fraction of electricity consumed may come from the grid, which is
more carbon intensive, to address intermittency of renewable energy.

K This is based on assumptions from the Hydrogen Analysis Production (H2A) Model from the National Renewable
Energy Laboratory (NREL).

x Soaking is the time between when a vehicle is powered off and when it starts again, so it indicates when vehicles
are not driving and may have an opportunity to charge.

X1 "Charging profiles for light-duty BEVs were generated using NREL's Electric Vehicle Infrastructure Projection
Tool (EVI-Pro) Lite.

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HD ZEVs is different between the proposal and reference case, we used different charging profiles for
distributing BEV demand by the hour of day. The charging profiles used for modeling the preliminary

Weekday Weekend

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23

Hour

control case is shown in

Figure 4-1.

Weekday Weekend

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23

Hour

Figure 4-1 Weekday and weekend charging profiles for HD BEVs in the control case

IPM requires grid demand to be geographically allocated by IPM region. We developed
regional allocation factors based on county-level CO2 emissions in the 2016v2 emissions
modeling platform.™-33 We used CO2 emissions as our basis for regional allocation because CO2
scales well with VMT while capturing differing fleet characteristics in different counties. IPM

xn The emissions modeling platform is a product of the National Emissions Inventory Collaborative consistent of
more than 245 employees of state and regional air agencies, EPA, and Federal Land Management agencies. It
includes a full suite of base year (2016) and projection year (2023 and 2028) emission inventories modeled using
EPA's full suite of emissions modeling tools, including MOVES, SMOKE, and CMAQ.

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includes a mapping of each county to an IPM region, which we used to aggregate county
allocation factors by IPM region.

4.3.3.2 EGUEmissions Modeling Methodology

The IPM runs we performed to estimate EGU emissions were based on preliminary reference
and control scenarios, and the IPM run for the control scenario did not account for the IRA.
Therefore, we developed a methodology to estimate the increase in EGU emissions from the
proposal and alternative, adjusted for the IRA.

We calculated emission factors that relate an increase in EGU emissions to an increase in HD
ZEV energy consumption. This approach does not yield perfectly accurate emissions estimates
because the power generation mix, and therefore EGU emissions, depend on the total energy
demand. However, we feel it is nonetheless illustrative of the general scope of upstream EGU
emissions impact we can expect from the proposal and the alternative.

We first calculated emission factors absent the IRA using the preliminary reference and
control IPM output. The only difference in IPM inputs between the runs is an increase in HD
ZEV adoption, so all emission changes between the two IPM runs are attributable to HD ZEV
adoption. We calculated an incremental EGU emission factor, which relates an increase in EGU
emissions to an increase in HD ZEV energy demand, for each pollutant. The calculation method
for an incremental EGU emission factor is shown in Equation 4-2.

. . . r Emissions control Emissionsreeerence

incremental EGU emission factor =

EnergyDemandcontroi — EnergyDemandreference

Equation 4-2 Calculation method of an incremental EGU emission factor

To account for the IRA's impact on EGU emissions, we then calculated scalar multipliers for
the incremental EGU emission factors using output from the IPM run of the reference case that
accounted for the IRA. The multiplier is the ratio of emissions absent the IRA to emissions with
the IRA, as shown in Equation 4-3.

rn/i 7j_- 7 ¦ EmissionsjRArej>erence

IRA multiplier = —-—;—;

Emissionsreference

Equation 4-3 Calculation method of an IRA multiplier, used to scale incremental EGU emission factors

We applied a scalar multiplier to each incremental EGU emission factor to calculate an IRA-
adjusted incremental EGU emission factor, as shown in Equation 4-4, for each pollutant. The
IRA-adjusted incremental EGU emission factors are what we used to calculate EGU emissions
impacts for the proposal and alternative.

IRA Adjusted incremental EGU emission factor

= incremental EGU emission factor * IRA multiplier

Equation 4-4 Calculation method of a final IRA-adjusted incremental EGU emission factor

Table 4-8 shows the IRA-adjusted incremental EGU emission factors we calculated for four
calendar years and five pollutants. These factors represent the increase in EGU emissions, in
U.S. tons, per terawatt-hour of increased grid demand from HD ZEVs. We calculated IRA-

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adjusted incremental EGU emissions factors for 2035, 2040, 2045, and 2050 because IPM was
run for only select years.

Table 4-8 IRA-adjusted incremental EGU emission factors used to estimate EGU emissions increases
attributable to additional HD ZEV adoption in the proposal

IRA-Adjusted Incremental EGU Emission Factor

Pollutant

(U.S. Tons / Terawatt-Hour)

2035

2040

2045

2050

Carbon Dioxide (CO2)

136,686

87,420

49,756

30,130

Nitrogen Oxides (NOx)

17.3

13.6

6.3

1.9

Particulate Matter (PM2.5)

7.5

2.9

1.8

Sulfur Dioxide (SO2)

18.3

7.2

2.2

Volatile Organic Compounds (VOC)

3.9

4.5

2.2

1.8

Table 4-8 shows that EGU emission factors decrease into the future, as higher-emitting power
generation technologies like coal and natural gas combustion are phased out in favor of
renewable sources. This is especially apparent in emissions factors of sulfur dioxide (SO2),
which decrease by 96.5% from 2035 to 2050.

To estimate the impact of the proposal and alternative on EGU emissions, we multiply the
IRA-adjusted incremental EGU emission factors by the additional HD ZEV energy demand
modeled for each scenario estimated in MOVES3.R3. For year-over-year inventories, we use the
emission factor from the year closest to each calendar year, such that 2027 through 2037 use the
rate from 2035, 2038 through 2042 use the rate from 2040, and so on. The rate from 2050 was
used to estimate EGU emissions from 2051 through 2055.

This methodology approximates how we may expect EGU emissions to increase driven by
increased HD ZEV adoption with the proposal and the alternative, but the calculated emission
inventory estimates are not likely to be identical to those that would result from running IPM for
the reference, proposal, and alternative. There are, therefore, several caveats and limitations in
the interpretation of the results from this analysis.

First, as described earlier in this section, we do not have IPM runs that directly correlate to the
reference case used throughout this proposal. Second, because there is no inventory calculated
for the reference case, relative comparisons between the proposal, alternative, and reference case
(such as percent changes) are not possible.

Third, by only considering the additional energy demand and energy consumption of HD
ZEVs, we implicitly capture how characteristics specific to their operation (e.g., geographic
distribution of HD ZEVs, the types of roads they drive on, and the time of day in which they may
typically operate and charge) affect EGU emissions. However, this method is not able to
quantitatively isolate these effects, nor is it able to partition EGU emissions to HD ZEVs of
specific vehicle types such as by source type, regulatory class, or model year.

Finally, our methodology is only an approximation and may not fully represent the true
impact of the IRA on EGU emissions, especially when considering the combined effects of the
IRA and the proposed CO2 emission standards.

4.3.3.3 Refinery Emissions Analysis Methodology

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We developed the refinery emission inventories from refinery emissions in the 2016v2
emissions modeling platform.34'35 We reviewed the facilities included in the 2016 refinery sector
and omitted facilities that did not produce gasoline or diesel fuel. We projected emissions from
the remaining facilities, which refine gasoline or diesel fuel, from 2032 to 2050 using growth
factors from the reference case modeled by EIA in its 2021 Annual Energy Outlook (AEO).28
Table 4-9 shows the estimated 2050 refinery emissions.

Table 4-9 2050 refinery emissions projected from 2016v2 emissions modeling platform

Pollutant

Projected emissions in 2050
(U.S. Tons)

Nitrogen Oxides (NOx)

71,525

Particulate Matter (PM2.5)

19,514

Sulfur Dioxide (SO2)

29,347

Volatile Organic Compounds (VOC)

58,675

After accounting for the amount of refinery activity and inventory associated with producing
gasoline and diesel fuel, we then adjusted the refinery inventory for 2050 using adjustment
factors derived from changes in fuel demand to account for onroad impacts that were not
included in AEO2021. In the reference case for this proposal, the adjustment factors accounted
for EPA's Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions
Standards29 and the HD ZEV adoption described in Chapter 4.3.1. The adjustment factors for the
proposal and alternative incorporated the estimated decrease in fuel demand resulting from
increased HD ZEV adoption described in Chapter 4.3.2.

We projected the change in petroleum demand and its effect on imported petroleum products
based on a comparison of two separate economic cases modeled by EIA in AEO2021: the Low
Economic Growth Case and the Reference Case.X111'34 The AEO Low Economic Growth Case
estimates lower refined product demand than that of the AEO Reference Case. Due to the
reduced refined product demand, AEO estimates reduced imports of crude oil refined products.
The two AEO cases project that, for a volume of reduced gasoline or diesel fuel demand, 84
percent of that gasoline or diesel reduction can be attributed to reduced crude oil imports and 7
percent can be attributed to imports of refined products.

We developed pollutant-specific adjustment factors based on reductions in liquid fuel demand
and applied them to the 2050 projected inventory to generate reference, proposal and alternative
inventories. These adjustment factors are presented in Table 4-10.

Table 4-10 Adjustment factors applied to 2050 refinery inventory

Pollutant

Reference

Proposal

Alternative

Nitrogen Oxides (NOx)

0.966

0.941

0.948

Particulate Matter (PM2.5)

0.967

0.945

0.951

Sulfur Dioxide (SO2)

0.970

0.949

0.954

Volatile Organic Compounds (VOC)

0.968

0.946

0.952

xm In this paragraph, Reference Case refers to the 2021 Annual Energy Outlook Reference Case, not the reference
case used elsewhere in this chapter to evaluate the impacts of the proposal and alternative.

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AEO2021 only projects out to 2050, so we used adjustment factors for 2050 and assumed that
the refinery inventory remained constant between 2050 and 2055.

We recognize that there is significant uncertainty in the impact reduced fuel demand has on
refinery emissions. If refineries do not decrease production in response to lower domestic
demand (for example, they could increase exports instead), we would project no emission
reductions from refineries rather than the reductions shown in Table 4-18.

4.4 National Downstream Emission Inventory Impacts of the Proposal

This section presents the impacts of the proposed CO2 emission standards and the alternative
on downstream emissions of GHGs and several criteria pollutants and air toxics. All emission
inventories were modeled using MOVES national domain, which includes the 50 states and the
District of Columbia but not any U.S. commonwealths or territories.

Because we anticipate an increase in ZEVs as a method to comply with the proposed CO2
standards for MYs 2027 through 2032 and later, we expect downstream reductions of additional
GHGs (methane and nitrous oxide) as well as reductions of criteria pollutants and toxics. We
modeled the proposed standards in MOVES3.R3 only by increasing the adoption of HD ZEVs
(including both BEVs and FCEVs), which means the driving factor behind all emission
reductions is the displacement of HD ICE vehicles with HD BEVs.

Chapter 4.4.1 presents the inventory changes for three analysis years: 2035, 2045, and 2055.
Chapter 4.4.2 presents year-over-year emission impacts from 2027 through 2055, including
cumulative emission reductions. Chapter 4.4.3 discusses these impacts in more detail, including
by vehicle type and fuel type, for calendar year 2055.

4.4.1 Analysis Year Impacts

Our estimates of the downstream emission reductions of GHGs that would result from the
proposed standards, relative to the emission inventory without the proposed standards, are
presented below in Table 4-11 for calendar years 2035, 2045, and 2055. Total GHG emissions,
or CO2 equivalent, are calculated by summing all GHG emissions multiplied by their 100-year
Global Warming Potential (GWP). The GWP values used in Table 4-11 are consistent with the
2007 IPCC Fourth Assessment Report (AR4)36 and documented in the Greenhouse Gas and
Energy Consumption Rates for Onroad Vehicles in MOVES3.R3 technical report.7

Table 4-11 Annual downstream heavy-duty GHG emission reductions from the proposed standards in

calendar years (CYs) 2035, 2045, and 2055

Pollutant

100-
year
GWP

CY 2035 Reductions

CY 2045 Reductions

CY 2055 Reductions

Million Metric
Tons

Percent

Million Metric
Tons

Percent

Million Metric
Tons

Percent

Carbon Dioxide (CO2)

13%

102

26%

125

30%

Methane (CH4)

0.004

0.015

24%

0.032

31%

Nitrous Oxide (N2O)

298

0.007

12%

0.013

24%

0.015

28%

C02 Equivalent (CC>2e)

...

13%

106

26%

130

30%

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In 2055, we estimate that the proposal would reduce emissions of CO2 by 30 percent, methane
by 31 percent, and N2O by 28 percent. This results in total greenhouse gas (CChe) reductions of
30 percent in 2055.

Table 4-12 contains the emission inventory impacts of the proposal for criteria pollutants and
air toxics.

Table 4-12 Annual downstream heavy-duty criteria pollutant and air toxic emission reductions from the
proposed standards in calendar years (CYs) 2035, 2045, and 2055

Pollutant

CY 2035 Reductions

CY 2045 Reductions

CY 2055 Reductions

U.S. Tons

Percent

U.S. Tons

Percent

U.S. Tons

Percent

Nitrogen Oxides (NOx)

16,232

56,191

21%

70,838

28%

Primary Exhaust PM2.5A

271

690

30%

967

39%

Volatile Organic Compounds (VOC)

6,016

11%

14,219

28%

20,775

37%

Sulfur Dioxide (SO2)

204

13%

414

27%

518

31%

Carbon Monoxide (CO)

98,889

11%

244,649

28%

349,704

35%

1,3-Butadiene

22%

46%

51%

Acetaldehyde

123

11%

298

30%

454

35%

Benzene

109

17%

281

41%

410

49%

Formaldehyde

217

27%

361

33%

Naphthalene0

10%

38%

45%

Ethylbenzene

11%

175

30%

266

41%

A Note that primary exhaust PM2.5 does not include brake wear and tire wear which are a significant source of
particulate emissions. After accounting for brake wear and tire wear, the total primary PM2.5 emission reductions
would be 3 percent in 2035, 10 percent in 2045, and 13 percent in 2055.

B Naphthalene includes both gas and particle phase emissions.

In 2055, we estimate the proposal would reduce downstream emissions of NOx by 28 percent,
PM2.5 by 39 percent, and VOC by 37 percent, and SO2 by 31 percent. Reductions in air toxics
range from 33 percent for formaldehyde to 51 percent for 1,3-butadiene.

4.4.2 Year-over-year Impacts

Table 4-13 shows the year-over-year GHG emission reductions that would result from the
proposed emission standards. Table 4-14 displays the year-over-year emission reductions that
would result from the proposed standards for a selection of criteria pollutants.

Table 4-13 Year-over-year GHG emission reductions from the proposed CO2 emission standards

Calendar
Year

CH4 Reductions

N2O Reductions

CO2 Reductions

CChe Reductions

MMT

Percent

MMT

Percent

MMT

Percent

MMT

Percent

2027

0.0002

0.3%

0.0003

0.5%

2.1

0.5%

2.2

0.5%

2028

0.0004

0.6%

0.0005

1.0%

4.6

1.1%

4.8

1.1%

2029

0.0006

0.9%

0.0009

1.7%

7.5

1.8%

7.8

1.8%

2030

0.001

1.6%

0.0015

2.8%

12.1

2.9%

12.5

2.9%

2031

0.0015

2.5%

0.0024

4.5%

18.8

4.6%

19.6

4.6%

2032

0.0022

3.6%

0.0035

6.6%

27.2

6.7%

28.3

6.7%

2033

0.003

4.9%

0.0046

8.6%

35.3

8.9%

36.8

8.8%

2034

0.0037

6.2%

0.0057

10.6%

43.2

10.9%

2035

0.0045

7.5%

0.0067

12.5%

50.8

12.9%

52.9

12.9%

2036

0.0054

9.2%

0.0077

14.2%

57.8

14.8%

60.2

14.8%

2037

0.0065

11.0%

0.0086

15.9%

64.5

16.6%

67.2

16.6%

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2038

0.0076

13.0%

0.0094

17.4%

70.7

18.3%

73.7

18.2%

2039

0.0087

14.9%

0.0101

18.8%

76.5

19.8%

79.7

19.7%

2040

0.0098

16.6%

0.0108

19.9%

81.8

21.2%

85.3

21.1%

2041

0.0109

18.2%

0.0114

21.1%

86.8

22.4%

90.4

22.4%

2042

0.0119

19.8%

0.012

22.1%

91.3

23.6%

95.2

23.5%

2043

0.013

21.2%

0.0125

22.9%

95.3

24.5%

99.4

24.5%

2044

0.014

22.6%

0.0129

23.7%

98.9

25.4%

103.1

25.4%

2045

0.0152

23.8%

0.0132

24.4%

102.1

26.2%

106.5

26.1%

2046

0.0164

25.0%

0.0136

24.9%

105.1

26.8%

109.6

26.8%

2047

0.0176

26.0%

0.0138

25.4%

107.6

27.4%

112.1

27.3%

2048

0.0189

26.7%

0.014

25.7%

109.6

27.9%

114.3

27.8%

2049

0.0203

27.7%

0.0142

26.1%

111.8

28.4%

116.6

28.3%

2050

0.0219

28.5%

0.0145

26.4%

114.3

28.8%

119.1

28.7%

2051

0.0235

29.2%

0.0147

26.7%

116.6

29.2%

121.6

29.1%

2052

0.0253

29.7%

0.0149

27.0%

118.8

29.5%

123.9

29.4%

2053

0.0272

30.1%

0.0151

27.2%

121

29.8%

126.2

29.7%

2054

0.0293

30.4%

0.0152

27.4%

123.1

30.1%

128.4

30.0%

2055

0.0315

30.6%

0.0154

27.6%

125.1

30.3%

130.5

30.2%

Table 4-14 Year-over-year emission inventory reductions for the proposed CO2 emission standards for select

criteria pollutants

Calendar
Year

NOx Reductions

Exhaust PM2.5 Reductions

VOC Reductions

U.S. Tons

Percent

U.S. Tons

Percent

U.S. Tons

Percent

2027

503

0.1%

265

0.3%

2028

1,093

0.1%

0.2%

590

0.8%

2029

1,800

0.3%

0.5%

983

1.4%

2030

2,934

0.5%

0.8%

1,518

2.2%

2031

4,813

0.9%

1.4%

2,231

3.4%

2032

7,113

1.4%

139

2.3%

3,146

5.0%

2033

9,846

2.1%

182

3.5%

4,111

6.9%

2034

12,782

3.0%

226

4.8%

5,071

8.8%

2035

16,232

4.0%

271

6.5%

6,016

10.9%

2036

20,413

5.4%

318

8.6%

6,959

12.8%

2037

25,445

7.1%

366

14.5%

7,898

15.3%

2038

30,681

9.0%

414

16.8%

8,444

17.4%

2039

35,557

10.9%

460

19.0%

9,737

19.3%

2040

40,077

12.8%

504

21.2%

10,575

21.2%

2041

44,144

14.7%

545

23.3%

11,368

22.6%

2042

47,822

16.4%

586

25.4%

12,135

24.2%

2043

50,975

17.9%

623

27.1%

12,857

25.6%

2044

53,752

19.3%

658

28.8%

13,551

27.1%

2045

56,191

20.5%

690

30.3%

14,219

28.3%

2046

58,361

21.7%

721

31.9%

14,864

29.3%

2047

60,171

22.7%

751

32.8%

15,526

30.3%

2048

61,734

23.6%

779

34.2%

16,159

31.5%

2049

63,303

24.5%

807

35.2%

16,805

32.4%

2050

64,871

25.2%

835

36.1%

17,469

33.5%

2051

66,304

25.9%

863

36.6%

18,129

34.1%

2052

67,614

26.5%

890

37.2%

18,808

35.0%

2053

68,803

27.0%

916

37.7%

19,474

35.7%

2054

69,869

27.5%

942

38.2%

20,128

36.4%

2055

70,838

27.9%

967

38.6%

20,775

37.0%

329

-------
Table 4-13 and Table 4-14 show that emission reductions would increase over time, as more
ICE vehicles are displaced by ZEVs. As ZEVs represent an increasing proportion of the HD
fleet, modeled emission reductions increase.

The warming impacts of GHGs are cumulative. Therefore, in Table 4-15, we present the
cumulative GHG reductions that we expect would result from the proposed standards, measured
in billion metric tons (BMT).

Table 4-15 Cumulative 2027-2055 downstream GHG emission reductions from the proposed CO2 emission

standards

Pollutant

Reduction in BMT

Percent Reduction

Carbon Dioxide (CO;)

2.2

18%

Methane (CH-t)

0.00035

17%

Nitrous Oxide (N2O)

0.00028

17%

CO;Equivalent (C( );e)

2.3

18%

Figure 4-2 shows how emission reductions accumulate over time, beginning in 2027 through
2055, the last year of our analysis. While Figure 4-2 only shows CChe emission reductions, it is
representative of how emission reductions accumulate for most GHGs, criteria pollutants, and air
toxics.

Figure 4-2 Cumulative and yearly emission reductions for CChe from the proposed standards from 2027

through 2055

330

-------
Figure 4-3, Figure 4-4, Figure 4-5 show yearly GHG inventories for the reference case and the
proposed emission standards. The emissions estimates presented represent the mass of each
pollutant and are not translated to represent emissions in terms of CO2 equivalency.

0.100-

p 0,075-

2
S

| 0.050-
>

«r
I
O

0.025 -

0.000-

Figure 4-3 Yearly methane inventory for the reference case and the proposed emission standards from 2027

through 2055

MOVES3.R3 models increasing methane emissions in the future based primarily on the
increased adoption of CNG vehicles. We expect the proposal to increase demand for ZEVs in the
2030s and therefore reduce demand for CNG. While we project there is still CNG growth in the
future, we expect the displacing of CNG vehicles with ZEVs would result in significant
reductions in methane emissions.

2030

2040
Calendar Year

2050

Reference — Proposal

331

-------
0.02

0.00

2030

2040
Calendar Year

2050

— Reference — Proposal

Figure 4-4 Yearly NiO inventory for the reference case and the proposed emission standards from 2027

through 2055

Absent the proposed rule, the N2O inventory is projected to grow through 2055 as heavy-duty
VMT is projected to increase. We expect the proposal would significantly reduce the number of
HD ICE vehicles as fleet turns over to ZEVs, and therefore N2O emissions are reduced through
the 2030s and 2040s.

332

-------
c

a>
>

O
O

400

300-

200-

100

0 -

2030

2040
Calendar Year

2050

Reference — Proposal

Figure 4-5 Yearly CChe inventory for the reference case and the proposed emission standards from 2027

through 2055

In the reference case, CO2 and CChe emissions are projected to decrease from 2027 through
most of the 2030s as I ID ZEV adoption grows and older vehicles (model years 2015 and earlier)
age out of the fleet. We project that an increase in HD VMT will eventually cause GHG
emissions to rise. While this trend applies to the proposal scenario also, we expect that the
increased HD ZEV adoption in the proposal would result in emissions declining into the 2040s
and a much lower upturn in the 2050s.

Figure 4-6, Figure 4-7, and Figure 4-8 show the yearly inventories for NOx, PM2.5, and VOC,
respectively.

333

-------
750000 -

500000 J

2500001

2030 2040 2050

Calendar Year

— Reference — Proposal

Figure 4-6 Yearly NOx inventory for the reference case and the proposed emission standards from 2027

through 2055

334

-------
15000

10000

5000

2030 2040 2050

Calendar Year

Reference — Proposal

Figure 4-7 Yearly primary exhaust PM2.5 inventory for the reference case and the proposed emission

standards from 2027 through 2055

335

-------
tn
C
o
\-

co
3

o
+—
c
a)
>
_c

O
O

75000 J

50000 -

25000 -

2030

2040
Calendar Year

2050

— Reference — Proposal

Figure 4-8 Yearly VOC inventory for the reference case and the proposed emission standards from 2027

through 2055

Due to the HD2027 Low NOx standards, NOx emissions are projected to decrease through
2055 in the reference case, but the adoption of ZEVs in the proposal would lead to additional
reductions. The PM2.5 inventory shows a decline through the 2030s with a notable drop from
calendar year 2036 to 2037, due to the complete fleet turnover of HD diesel vehicles without
diesel particulate filters (DPFs). The HD PM2.5 inventory shows little change afterward in the
reference case, but we estimate the inventory with the proposed standards would continue to
decrease modestly. Finally, the VOC emission inventory shows a similar trend as CO2, with
emissions projected to decrease from 2027 through the 2030s in the reference case while
projected increased ZEV adoption in the proposal pushes these reductions into the 2040s and
slows the increase of emissions in the 2050s.

4.4.3 Detailed Emission Impacts

This section presents the emission reductions we estimate would result from the proposed
standards, including emission reductions by regulatory class, source type, fuel type, and emission
process. For the purposes of this section, we combine tailpipe and crankcase processes, so that
the running process represents both running tailpipe and crankcase processes. This is also the
case for starts and extended idle.

In our modeling of the reference case and the proposed standards, we model a combination of
technologies, including both ICE vehicles and ZEVs. The emission reductions projected for the
proposed standards represent the reduction of emissions due to a greater adoption of ZEVs
phasing out ICE vehicles in the HD fleet. Modeled emission reductions do not indicate that we
reduced emission rates of ICE vehicles in MOVES.

336

-------
Figure 4-9 shows the detailed breakdown of emission reductions of carbon dioxide (CO2) that
would result from the proposed emission standards.

1.2e+08

8 0e+07

4.0e+07

0.0e+00

1 2e+08 -

8.0e+07 -

P 4 0e+07

0 Oe+OO -

c
.0

1 2e+08

c
o

E 8 0e+07
lu

4.0e+07 -

0.0e+00

1.2e+08

8.0e+07

4.0e+07

0.0e+00

CY 2035

CY 2045

CY 2055

CY 2035

CY 2045

CY 2055

CY 2035 CY 2045 CY 2055

MOVES Regulatory Class

| 42-LHD45
46-MHD67
1 47-HHD8

48-Urban Bus
I 49-Gliders

MOVES Source Type

41-Other Buses
| 42-Transit Bus
| 43-School Bus

51-Refuse Truck

52-Single Unit Short-haul Truck

53-Single Unit Long-haul Truck
| 54-Motor Home

61-Combination Short-haul Truck
| 62-Combination Long-haul Truck

MOVES Fuel Type

1-Gasoline
| 2-Diesel
B 3-CNG

MOVES Emission Process

| 1-Running Exhaust
| 2-Starts Exhaust

1 90-Extended Idle Exhaust
I 91-DieseI APU Exhaust

CY 2035 CY 2045

CY 2055

Figure 4-9 CCh reductions from the proposed standards by regulatory class and source type for calendar

years (CY) 2035, 2045, and 2055

337

-------
Figure 4-10 shows estimated methane emission reductions that would result from the
proposed emission standards by regulatory class, source type, and fuel type, and emission
process.

30000 -

20000 -

10000-

30000 H

20000 -

10000-1

¦o

a)
OL

30000 -

E 20000
lU

10000i

30000 i

20000 J

10000-

CY 2035

CY 2045 CY 2055

CY 2035

CY 2045 CY 2055

CY 2035

CY 2045

CY 2055

MOVES Regulatory Class

| 42-LHD45
46-MHD67
| 47-HHD8
48-Urban Bus

MOVES Source Type

41-Other Buses
| 42-Transit Bus
| 43-School Bus
51 Refuse Truck

52-Single Unit Short-haul Truck

53-Single Unit Long-haul Truck
| 54-Motor Home

61-Combination Short-haul Truck
I 62-Combination Long-haul Truck

MOVES Fuel Type

1-Gasoline
| 2-Diesel
3-CNG

MOVES Emission Process

| 1-Running Exhaust
| 2-Starts Exhaust

90-Extended Idle Exhaust
I 91-Diesel APU Exhaust

CY 2035

CY 2045

CY 2055

Figure 4-10 Methane reductions from the proposed standards by regulatory class, source type, and fuel type

for CYs 2035, 2045, and 2055

338

-------
CNG vehicles represent the largest source of HD methane emissions in MOVES3.R3 despite
their small population. This is because CNG vehicles have methane emission rates that are at
least 30 times greater than comparable gasoline and diesel vehicles. We expect most methane
reductions, therefore, would come from displacing CNG vehicles with ZEVs. MOVES3.R3 only
models CNG for the Class 8 and urban bus regulatory classes (IDs 47 and 48), so we expect that
all CNG methane emission reductions come from ZEV adoption for buses and heavy heavy-duty
trucks. We expect there would be modest methane emission reductions from displacement of
gasoline and diesel vehicles with ZEVs as well.

Figure 4-11 shows the NOx emission reductions that we expect would result from the
proposed emission standards by regulatory class, source type, and fuel type.

339

-------
60000

40000

20000

60000 -I

40000 H

,2 20000-
16

C£

c
o

60000

40000 -1

20000 J

60000 -

40000 -I

20000

CY 2035

CY 2045

CY 2055

CY 2035

CY 2045

CY 2055

CY 2035

CY 2045

CY 2055

MOVES Regulatory Class

| 42-LHD45
46-MHD67
| 47-HHD8

48-Urban Bus

49-Gliders

MOVES Source Type

41-Other Buses
j 42-Transit Bus
| 43-School Bus

51-Refuse Truck

52-Single Unit Short-haul Truck

53-Single Unit Long-haul Truck
| 54-Motor Home

61-Combination Short-haul Truck
I 62-Combination Long-haul Truck

MOVES Fuel Type

1-Gasoline
| 2-Diesel
I 3-CNG

MOVES Emission Process

\ 1-Running Exhaust
| 2-Starts Exhaust

90-Extended Idle Exhaust
I 91-Diesel APU Exhaust

CY 2035

CY 2045

CY 2055

Figure 4-11 NOx reductions from the proposed standards by regulatory class, source type, and fuel type for

CYs 2035, 2045, and 2055

Just as HD methane emissions are driven by CNG vehicles, HD NOx emissions are driven by
diesel vehicles. We expect that most NOx reductions would come from ZEV adoption in

340

-------
combination trucks because they represent a large portion of diesel vehicles now and in the
future.

Figure 4-12 shows the modeled primary exhaust PM2.5 emission reductions that would result
from the proposal by regulatory class, source type, fuel type, and emission process.

1000-

750 -

500 -

250 -

1000-

750 -

500

250 -

(/)
3

1000

S 750

E
uj

500 -

250

0 J

1000-

750 -

500 -

250 -

CY 2035

CY 2045

CY 2055

CY 2035

CY 2045

CY 2055

CY 2035 CY 2045

CY 2055

MOVES Regulatory Class

| 42-LHD45
46-MHD67
| 47-HHD8

48-Urban Bus

49-Gliders

MOVES Source Type

41-Other Buses

42-Transit Bus
| 43-School Bus

51-Refuse Truck

52-Single Unit Short-haul Truck

53-Single Unit Long-haul Truck
| 54-Motor Home

61-Combination Short-haul Truck
| 62-Combination Long-haul Truck

MOVES Fuel Type

1-Gasoline
| 2-Diesel
I 3-CNG

MOVES Emission Process

| 1-Running Exhaust
| 2-Starts Exhaust
. | 90-Extended Idle Exhaust
I 91-DieselAPU Exhaust

CY 2035 CY 2045

CY 2055

Figure 4-12 Primary exhaust PM2.5 reductions from the proposed standards by regulatory class, source type,
fuel type, and emission process for CY 2035,2045, and 2055

341

-------
We estimate that the proposal would result in greater PM2.5 emission reductions from light and
medium HD vehicles than heavy HD vehicles. Current and future gasoline HD vehicles are
expected to have higher PM emission rates than comparable diesel or CNG vehicles, which
means the displacement of gasoline vehicles with ZEVs is expected to drive most of the PM2.5
reductions. The most significant source of reductions is expected to be from single-unit short-
haul trucks that are Class 5 and below. We note that the primary exhaust PM2.5 emissions do not
include brake wear or tire wear.

Figure 4-13 shows modeled VOC emission reductions that we expect would result from the
proposed CO2 emission standards by regulatory class, source type, fuel type, and emission
process. The detailed emission reductions of VOC are representative of reductions for air toxic
emissions, such as benzene, formaldehyde, and 1,3-butadiene.

342

-------
20000

15000

20000 -

15000J

10000

5000 -

w
O

•o

a 20000

15000

10000

5000 -

20000-

15000 "

100001

5000 -

CY 2035

CY 2045 CY 2055

CY 2035

CY 2045 CY 2055

CY 2035

CY 2045 CY 2055

MOVES Regulatory Class

| 42-LHD45
46-MHD67
| 47-HHD8
48-Urban Bus
1 49-GIiders

MOVES Source Type

| 41-Other Buses
42-Transit Bus
| 43-School Bus

51-Refuse Truck

52-Single Unit Short-haul Truck

53-Single Unit Long-haul Truck
| 54-Motor Home

61-Combination Short-haul Truck
I 62-Combination Long-haul Truck

MOVES Fuel Type

1-Gasoline
| 2-Diesel
.. 3-CNG

MOVES Emission Process

| 1-Running Exhaust
| 2-Starts Exhaust
| 11-Evap: Permeation
¦ 12-Evap: Vapor Venting
13-Evap: Fuel Leaks
18-Refueling: Vapor Loss
| 19-Refueling: Spillage

90-Extended Idle Exhaust
I 91-Diesel APU Exhaust

CY 2035

CY 2045 CY 2055

Figure 4-13 VOC reductions from the proposed standards by regulatory class, source type, and fuel type for

CYs 2035, 2045, and 2055

343

-------
Most heavy-duty VOC emissions come from gasoline-powered vehicles. Emissions occur
during gasoline combustion (especially during starts before emission controls are fully effective)
while a vehicle is running; evaporation while a vehicle is parked; or evaporation while a vehicle
is refueling. As a result, we expect most VOC emissions reductions would be from ZEVs
displacing HD gasoline vehicles, which are mostly light HD vehicles such as delivery trucks or
gasoline buses.

In summary, we expect the displacement of HD ICE vehicles of all fuel types with HD ZEVs
would drive broad emission reductions—we expect the displacement of diesel HD vehicles will
be the primary source of NOx reductions; we project the displacement of gasoline light HD
trucks will be the primary source of PM2.5 and VOC reductions; and we anticipate the
displacement of HD CNG vehicles will be the primary source of methane reductions.

4.5 National Upstream Emission Inventory Impacts of the Proposal

We expect that downstream emissions reductions would result from the proposed CO2
emission standards based on increased adoption of HD ZEVs. Because the energy to operate
ZEVs comes from electricity, we expect the proposed standards would increase emissions from
electricity generation units (EGUs). We also estimate that the proposed emission standards
would reduce demand for liquid fuel and reduce emissions from refineries.

EGU emissions estimates are based on IPM output as described in Chapter 4.3.3. IPM
produces emissions estimates for a more limited set of pollutants than MOVES. The only
greenhouse gas IPM estimates is CO2 (MOVES also estimates CH4 and N2O) and the only
criteria pollutants IPM estimates are NOx, PM2.5, VOCs, and SO2 (MOVES also estimates CO).
Since IPM does not directly output air toxics, we do not present air toxic emissions from EGUs
in this proposal.

As discussed in Chapter 4.3.3.2, the methodology used to estimate upstream EGU emissions
cannot estimate an EGU emissions inventory in absolute tons for the reference scenario.
Therefore, relative comparisons between the reference and the control scenarios are not possible
and only the emissions impacts in absolute tons from the proposal and alternative are presented.

As discussed in Chapter 4.3.3.3, our methodology for estimating refinery emissions is limited
to one analysis year (2055) and only certain non-GHG pollutants (NOx, PM2.5, VOC, and SO2).

4.5.1 Analysis Year Impacts

Our estimates of the changes in CO2 emissions from EGUs due to the proposed standards,
relative to the reference case, are presented below in Table 4-16 for calendar years 2035, 2045,
and 2055.

Table 4-16 Annual upstream EGU CO2 emission increases from the proposed standards in calendar years

(CYs) 2035, 2045, and 2055

Pollutant

Increase in EGU Emissions (MMT)

CY 2035

CY 2045

CY 2055

Carbon Dioxide (CO2)

344

-------
In 2055, we estimate the proposal would increase EGU emissions of CO2 by 11 million metric
tons, compared to 20 million metric tons in 2035. The EGU impacts are projected to decrease
over time due to expected changes in the power generation mix.

Table 4-17 contains our estimates of EGU emission changes from the proposal for some
criteria pollutants.

Table 4-17 Annual upstream EGU criteria pollutant emission increases from the proposed standards in

calendar years (CYs) 2035, 2045, and 2055

Pollutant

Increase in EGU Emissions (U.S. Tons)

CY 2035

CY 2045

CY 2055

Nitrogen Oxides (NOx)

2,821

2,226

787

Primary PM2.5

1,216

1,043

751

Volatile Organic Compounds (VOC)

629

772

754

Sulfur Dioxide (SO2)

9,937

2,552

912

In 2055, we estimate the proposal would increase EGU emissions of NOx by 787 tons, PM2.5
by 751 tons, VOC by 754 tons, and SO2 by 912 tons.

The projected impacts on refinery emissions in 2055 for the proposal are presented in Table
4-18.

Table 4-18 Emission reductions from refineries in CY 2055 from the proposal

Pollutant

Reduction in Refinery Emissions (U.S. Tons)

CY 2055

NOx

1,785

PM2.5

436

VOC

1,227

S02

642

4.5.2 Year-over-year Impacts

The projected change in EGU emissions resulting from increased HD ZEV adoption depends
on two factors. The first is the amount of additional energy demand from HD ZEVs, and the
second is the power generation mix for EGUs. While MOVES estimates monotonic increases in
HD ZEV energy demand starting in 2027 from the proposed standards, IPM estimates decreased
EGU emissions as fossil fuel combustion is phased out in favor of renewable energy sources.
When the Inflation Reduction Act's power sector provisions are accounted for, EGU emission
reductions over time are even larger.

Due to the methodology we used to estimate EGU emissions impacts, as discussed in Chapter
4.3.3.2, the estimated emission impacts are more uncertain in nearer future years than farther out
years. This is in part because the preliminary proposal scenario for which we ran IPM is most
similar to the proposal in later years.

Table 4-19 shows estimated year-over-year CO2 emission increases that are expected to result
from the proposed CO2 emission standards. Table 4-20 displays the estimated year-over-year
emission increases that are expected to result from the proposed standards for criteria pollutants.

345

-------
Table 4-19 Year-over-year EGU CO2 emission increases reflecting the proposed CO2 emission standards

Calendar

EGU CO2 Emissions Increase

Year

(Million Metric Tons)

2027

0.5

2028

1.0

2029

1.6

2030

3.2

2031

6.1

2032

9.7

2033

13.2

2034

16.7

2035

20.2

2036

21.8

2037

22.8

2038

23.1

2039

23.0

2040

22.3

2041

21.7

2042

20.8

2043

19.5

2044

17.9

2045

16.0

2046

15.2

2047

14.1

2048

13.0

2049

11.9

2050

10.7

2051

10.9

2052

11.0

2053

11.2

2054

11.3

2055

11.4

Table 4-20 Year-over-year EGU emission inventory increases for criteria pollutants reflecting the proposed

CO2 emission standards

Calendar
Year

EGU Emissions Increase (U.S. Tons)

NOx

voc

Primary PM2.5

SO2

2027

224

2028

136

479

2029

222

781

2030

442

191

1,557

2031

846

189

365

2,981

2032

1,349

301

582

4,752

2033

1,846

412

796

6,503

2034

2,340

522

1,009

8,241

2035

2,821

629

1,216

9,937

2036

3,137

756

1,356

9,933

2037

3,393

884

1,472

9,424

2038

3,590

1,012

1,562

8,431

346

-------
2039

3,727

1,140

1,628

6,991

2040

3,809

1,266

1,670

5,144

2041

3,627

1,211

1,602

4,822

2042

3,372

1,132

1,503

4,392

2043

3,045

1,030

1,373

3,858

2044

2,660

909

1,218

3,240

2045

2,226

772

1,043

2,552

2046

1,966

766

988

2,256

2047

1,680

754

923

1,930

2048

1,375

738

852

1,582

2049

1,062

723

779

1,224

2050

738

707

704

855

2051

749

718

715

868

2052

760

728

725

881

2053

770

738

735

892

2054

779

746

743

903

2055

787

754

751

912

From 2027 through the 2030s, EGU emission increases are expected to start small and grow
as HD ZEV adoption drives greater increases in energy demand. But through the 2040s, a
substantial increase in the use of renewable energy sources is expected to take place in the
national power generation mix, driven in part by the IRA. This is expected to lead to decreases in
EGU emissions at a national level, including decreases in EGU emissions attributable to HD
ZEVs and the proposed standards.

Figure 4-14 shows the same information as Table 4-19. The plot shows the projected increase
in EGU emissions, peaking in 2039 before dropping until 2050. Figure 4-15 shows that the same
trend is projected for criteria pollutants, where all but SO2 emissions are projected to peak in
2040. SO2 emissions are projected to peak in 2035. SO2 emissions are primarily driven by power
generation using coal, which is the first fossil fuel expected to be phased out, especially when
accounting for the IRA.

347

-------
0

2030

2040
Calendar Year

2050

Figure 4-14 Yearly CO2 emissions changes from EGUs from the proposed CO2 emission standards from 2027

through 2055

c/)
3

a)
o>

t/)
V)

£
UJ

10000-

7500

5000

2500

2030

2040
Calendar Year

2050

Figure 4-15 Yearly criteria pollutant emissions increases from EGUs from the proposed CO2 emission

standards from 2027 through 2055

348

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In Table 4-21, we present the cumulative CO2 increases from EGUs that we expect would
result from the proposed standards, measured in billion metric tons (BMT).

Table 4-21 Cumulative 2027-2055 EGU CO2 emission increases from the proposed CO2 emission standards

Pollutant

EGU CO2 emissions increase (BMT)

Carbon Dioxide (CO2)

0.4

4.6 Net Emissions Impacts of the Proposal

This section compares the modeled reduction in downstream emissions to the modeled
increase in upstream EGU emissions and presents the estimated net impact of the proposed CO2
emission standards.

While we present a net emissions impact of the proposed standards, it is important to note that
some upstream emission sources are not included in the analysis. We did not quantify emissions
changes associated with producing or extracting crude or transporting crude or refined fuels that
we expect to result from reduced demand for refined fuels. Therefore, this analysis likely
underestimates the net emissions reductions that may result from the proposal.

4.6.1 Analysis Year Impacts

Table 4-22 shows a summary of the estimated downstream, upstream, and net CO2 emission
impacts of the proposed standards relative to the reference case (i.e., the inventory without the
proposed standards), in million metric tons, for calendar years 2035, 2045, and 2055.

Table 4-22 Annual net CO2 emission impacts3 from the proposed standards in calendar years (CYs) 2035,

2045, and 2055

Pollutant

CY 2035 Impacts (MMT)

CY 2045 Im]

jacts (MMT)

CY 2055 Impacts (MMT)

Downstream

EGU

Net

Downstream

EGU

Net

Downstream

EGU

Net

C02

-51

-31

-102

-86

-125

-114

a We present emissions reductions as negative numbers and emission increases as positive numbers.

In 2055, we estimate the proposal would result in a net decrease of 114 million metric tons in
CO2 emissions. The net decreases become larger between 2035 and 2055 as the HD fleet turns
over and the power grid uses less fossil fuels.

In Table 4-23, we present the cumulative net CO2 emissions impact that we expect would
result from the proposed standards, accounting for downstream emission reductions and EGU
emission increases. Overall, we estimate the proposal would result in a net reduction of 1.8
billion metric tons of CO2 emissions from 2027 to 2055.

Table 4-23 Cumulative 2027-2055 EGU CO2 emission impacts3 (in BMT) reflecting the proposed CO2

emission standards

Pollutant

Downstream

EGU

Net

Carbon Dioxide (CO2)

-2.2

0.4

-1.8

a We present emissions reductions as negative numbers and emission increases
as positive numbers.

349

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Table 4-24 contains a summary of the modeled net impacts of the proposed CO2 emission
standards on criteria pollutant emissions considering downstream and EGUs, relative to the
reference case (i.e., without the proposed standards), for calendar years 2035 and 2045. Table
4-25 contains a similar summary for calendar year 2055 that includes estimates of net impacts of
refinery, EGU, and downstream emissions.

Table 4-24 Annual net impacts3 on criteria pollutant emissions from the proposed CO2 emission standards in

calendar years (CYs) 2035 and 2045

Pollutant

CY 2035 Impacts (U.S. Tons)

CY 2045 Impacts (U.S. Tons)

Downstream

EGU

Net

Downstream

EGU

Net

NOx

-16,232

2,821

-13,411

-56,191

2,226

-53,966

PM2.5

-271

1,216

945

-690

1,043

352

VOC

-6,016

629

-5,387

-14,219

772

-13,447

S02

-204

9,937

9,732

-414

2,552

2,138

a We present emissions reductions as negative numbers and emission increases as positive
numbers.

Table 4-25 Net impacts3 on criteria pollutant emissions from the proposed CO2 emission standards in CY

2055

Pollutant

CY 2055 Impacts (U.S. Tons)

Downstream

EGU

Refinery

Net

NOx

-70,838

787

-1,785

-71,836

PM2.5

-967

751

-436

-652

VOC

-20,775

754

-1,227

-21,248

S02

-518

912

-642

-248

a We present emissions reductions as negative numbers and
emission increases as positive numbers.

By 2055, when considering downstream, EGU, and refinery emissions, we estimate a net
decrease in emissions from all pollutants modeled (i.e., NOx, PM2.5, VOC, and SO2). In earlier
years, when considering only downstream and EGU emissions, we estimate net decreases of
NOx and VOC emissions, but net increases of PM2.5 and SO2 emissions. These increases
become smaller over time.

Overall, we estimate that the proposal will lead to net reductions in emissions of most
pollutants because downstream emission reductions tend to outpace EGU emission increases. We
estimate that reductions will start small and increase from 2027 through 2055. It is possible there
are increases in emissions of PM2.5 and SO2 in the nearer term as the electricity generation mix
still relies on a relatively higher proportion of fossil fuels. While we do not have refinery
emission impacts estimated for all calendar years, it is possible that refinery emission reductions
combined with downstream emission reductions also outpace EGU emission increases. In 2055,
for example, we estimate that refinery and downstream emission reductions exceed EGU
emission increases of SO2.

4.6.2 Year-over-year Impacts

Figure 4-16 and Table 4-26 show our estimated year-over-year net CO2 emission impacts that
would result from the proposed CO2 emission standards.

350

-------
2030 2040 2050

Calendar Year

Figure 4-16 Year-over-year net CO2 emission impacts of the proposed standards from 2027 through 2055
Table 4-26 Year-over-year net CO2 emission impacts3 of the proposed standards, in MMT

Calendar Year

Downstream

EGU

Net

2027

-2.1

0.5

-1.7

2028

-4.6

1.0

-3.6

2029

-7.5

1.6

-5.9

2030

-12.1

3.2

-8.9

2031

-18.8

6.1

-12.8

2032

-27.2

9.7

-17.5

2033

-35.3

13.2

-22.1

2034

-43.2

16.7

-26.5

2035

-50.8

20.2

-30.6

2036

-57.8

21.8

-36.0

2037

-64.5

22.8

-41.7

2038

-70.7

23.1

-47.5

2039

-76.5

23.0

-53.5

2040

-81.8

22.3

-59.5

2041

-86.8

21.7

-65.1

2042

-91.3

20.8

-70.6

2043

-95.3

19.5

-75.9

2044

-98.9

17.9

-81.0

2045

-102.1

16.0

-86.1

2046

-105.1

15.2

-89.9

2047

-107.6

14.1

-93.4

2048

-109.6

13.0

-96.6

2049

-111.8

11.9

-100.0

2050

-114.3

10.7

-103.6

2051

-116.6

10.9

-105.7

2052

-118.8

11.0

-107.8

351

-------
2053

-121.0

11.2

-109.8

2054

-123.1

11.3

-111.8

2055

-125.1

11.4

-113.7

a We present emissions reductions as negative numbers
and emission increases as positive numbers.

Downstream emissions are projected to decrease monotonically from 2027 through 2055 as
HD ZEV adoption grows and the fleet turns over. EGU emissions resulting from the increased
HD ZEV adoption are projected to increase until 2039, at which time we expect they will start
decreasing. Overall, the downstream emission reductions are anticipated to be greater than the
EGU emissions increases for all calendar years.

Figure 4-17, Figure 4-18, and Table 4-27 show our estimated year-over-year net emission
impacts that would result from the proposed CO2 emission standards for NOx and VOC.
Estimates of emissions of these pollutants show the same trends as CO2, except to note that we
estimate EGU emissions of NOx and VOC are expected to peak in 2040 rather than 2039.

CO
D

in
C
.O

in
in

-20000

-40000

-60000

Emissions Source

— Downstream

— EGU

— Net

2030

2040
Calendar Year

2050

Figure 4-17 Year-over-year net NOx emission impacts of the proposed standards from 2027 through 2055

352

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2030 2040 2050

Calendar Year

Figure 4-18 Year-over-year net VOC emission impacts of the proposed standards from 2027 through 2055

Table 4-27 Year-over-year net emission impacts" of the proposed standards for NOx and VOC

Calendar
Year

NOx Emission Impacts (U.S. Tons)

VOC Emission Impacts (U.S. Tons)

Downstream

EGU

Net

Downstream

EGU

Net

2027

-503

-439

-265

-251

2028

-1,093

136

-958

-590

-559

2029

-1,800

222

-1,579

-983

-934

2030

-2,934

442

-2,492

-1,518

-1,419

2031

-4,813

846

-3,966

-2,231

189

-2,043

2032

-7,113

1,349

-5,764

-3,146

301

-2,845

2033

-9,846

1,846

-8,000

-4,111

412

-3,699

2034

-12,782

2,340

-10,442

-5,071

522

-4,549

2035

-16,232

2,821

-13,411

-6,016

629

-5,387

2036

-20,413

3,137

-17,276

-6,959

756

-6,203

2037

-25.445

3,393

-22,051

-7,898

884

-7,014

2038

-30,681

3,590

-27,092

-8,444

1,012

-7,832

2039

-35,557

3,727

-31,830

-9,737

1.140

-8.597

2040

-40,077

3,809

-36,268

-10,575

1,266

-9,309

2041

-44.144

3,627

-40,517

-11,368

1,211

-10,157

2042

-47,822

3,372

-44,450

-12,135

1,132

-11,003

2043

-50,975

3,045

-47,929

-12,857

1.030

-11,827

2044

-53,752

2,660

-51,093

-13,551

909

-12,642

2045

-56,191

2,226

-53,966

-14,219

772

-13,447

2046

-58,361

1,966

-56,395

-14,864

766

-14,098

2047

-60,171

1,680

-58,491

-15,526

754

-14,772

353

-------
2048

-61,734

1,375

-60,359

-16,159

738

-15,421

2049

-63,303

1,062

-62,242

-16,805

723

-16,083

2050

-64,871

738

-64,134

-17,469

707

-16,762

2051

-66,304

749

-65,555

-18,129

718

-17,411

2052

-67,614

760

-66,854

-18,808

728

-18,079

2053

-68,803

770

-68,033

-19,474

738

-18,736

2054

-69,869

779

-69,090

-20,128

746

-19,382

2055

-70,838

787

-70,051

-20,775

754

-20,021

a We present emissions reductions as negative numbers and emission increases as positive numbers

Figure 4-19, Figure 4-20, and Table 4-28 show the estimated net emission impacts of the
proposed standards on emissions of primary PM2.5 and sulfur dioxide.

in
b

TO
CL

O-

Figure 4-19

-10001

2030

2040
Calendar Year

2050

Year-over-year net PM2.5 emission impacts of the proposed standards from 2027 through 2055

1000

Emissions Source

— Downstream

— EGU

— Net

354

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10000"

1 1 1

2030 2040 2050

Calendar Year

Figure 4-20 Year-over-year net SCh emission impacts of the proposed standards from 2027 through 2055
Table 4-28 Year-over-year net emission impacts" of the proposed standards for PM2.5 and SCh

7500

Emissions Source

— Downstream

— EGU

— Net

Calendar
Year

PM2.5 Emission Impacts (U.S. Tons)

SCh Emission Impacts (U.S. Tons)

Downstream

EGU

Net

Downstream

EGU

Net

2027

-11

-9

224

215

2028

-25

-19

479

460

2029

-42

-31

781

750

2030

-64

191

126

-50

1,557

1,507

2031

-97

365

268

-77

2,981

2,905

2032

-139

582

442

-110

4,752

4,642

2033

-182

796

614

-142

6,503

6,361

2034

-226

1,009

783

-174

8,241

8,067

2035

-271

1,216

945

-204

9,937

9,732

2036

-3 i 8

1,356

1,038

-232

9,933

9,701

2037

-366

1.472

1.105

-259

9,424

9,165

2038

-414

1,562

1,148

-284

8,431

8,147

2039

-460

1,628

1.168

-308

6,991

6,683

2040

-504

1,670

1,167

-330

5,144

4.814

2041

-545

1,602

1,057

-350

4.822

4,472

2042

-586

1,503

917

-369

4,392

4,023

2043

-623

1,373

750

-386

3,858

3,473

2044

-658

1,2 i 8

560

-401

3,240

2,839

2045

-690

1,043

352

-414

2,552

2,138

2046

-721

988

266

-427

2,256

1,829

2047

-751

923

172

-438

1,930

1,491

2048

-779

852

-447

1,582

1.134

2049

-807

779

-28

-457

1,224

767

355

-------
2050

-835

704

-131

-468

855

387

2051

-863

715

-148

-479

868

390

2052

-890

725

-165

-489

881

392

2053

-916

735

-182

-499

892

393

2054

-942

743

-199

-509

903

394

2055

-967

751

-216

-518

912

394

a We present emissions reductions as negative numbers and emission increases as positive numbers.

We estimate a net decrease in PM2.5 emissions beginning in 2049, and a net increase in
emissions of SO2 in all years.

4.7 Comparison Between the Proposal and the Alternative

The alternative has both a less aggressive phase-in of emissions standards from 2027 through
2031 and a less stringent ending standard for model years 2032 and beyond. Both the proposal
and alternative were modeled in MOVES3.R3 by increasing ZEV adoption of HD vehicles,
which means we model the alternative as displacing fewer ICE vehicles in favor of ZEVs as
compared to the proposal. In general, we expect to have both lower downstream emission
reductions and lower upstream EGU emission increases when compared to the proposal.

4.7.1 Downstream Emission Inventory Comparison

Our estimates of the downstream emission reductions of GHGs that would result from the
alternative, relative to the emission inventory of the reference case, are presented below in Table
4-29. Total GHG emissions, or CO2 equivalent, are calculated by summing all GHG emissions
multiplied by their 100-year GWP.

Table 4-29 Annual downstream heavy-duty GHG emission reductions from the alternative in calendar years

(CY) 2035, 2045, and 2055

Pollutant

100-

CY 2035 Reductions

CY 2045 Reductions

CY 2055 Reductions

year
GWP

Million
Metric Tons

Percent

Million
Metric Tons

Percent

Million
Metric Tons

Percent

Carbon Dioxide (CO2)

19%

22%

Methane (CH4)

0.003

0.011

17%

0.022

22%

Nitrous Oxide (N2O)

298

0.005

0.009

17%

0.011

20%

CO2 Equivalent (CC>2e)

...

19%

22%

Our estimated GHG emission reductions for the alternative are lower than for the proposal. In
2055, we estimate that the alternative would reduce emissions of CO2 by 22 percent (the
proposal's estimate is 30 percent), methane by 22 percent (the proposal's estimate is 31 percent),
and N2O by 20 percent (the proposal's estimate is 28 percent). The resulting total GHG
reduction, in C02e, is 22 percent for the alternative versus 30 percent for the proposal.

Figure 4-21 shows the year-over-year inventory of total HD GHG emissions (C02e) in the
reference case as well as for the proposal and alternative. It shows that the slower phase-in and
lower ending standards of the alternative result in lower overall GHG reductions compared to the
proposal.

356

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& 2e-04 -

% 1e-04 "

Oe+OO -

2030 2040 2050

Calendar Year

— Reference —1 Proposal — Alternative

Figure 4-21 Yearly CChe inventory for the reference case, proposed standards, and alternative from 2027

through 2055

Table 4-30 presents the cumulative GHG reductions that would result from the proposed
standards and the alternative in 2055, in billion metric tons (BMT).

Table 4-30 Cumulative 2027-2055 downstream GHG emission reductions from the proposed emission

standards and the alternative

Pollutant

Proposal GHG Reductions

Alternative GHG Reductions

BMT

Percent

BMT

Percent

Carbon Dioxide (COj)

2.2

18%

1.6

13%.

Methane (CH4)

0.00035

17%

0.00025

12%

Nitrous Oxide (N2O)

0.00028

17%

0.0002

12%

CO; Equivalent (COae)

2.3

18%

1.6

13%

Consistent with Table 4-29, the cumulative GHG emission reductions are expected to be
smaller for the alternative than the proposal. Cumulative emission reductions from the alternative
for all GHGs (in CChe) are projected to be about 700 million metric tons smaller than the
cumulative GHG emission reductions from the proposal, roughly 5 percent of the total HD GHG
emissions from 2027 through 2055.

The downstream emission reductions for criteria pollutants and air toxics that would result
from the alternative are presented in Table 4-31.

357

-------
Table 4-31 Annual downstream heavy-duty criteria pollutant and air toxic emission reductions from the
alternative in calendar years (CYs) 2035,2045, and 2055

Pollutant

CY 2035 Reductions

CY 2045 Reductions

CY 2055 Reductions

U.S. Tons

Percent

U.S. Tons

Percent

U.S. Tons

Percent

Nitrogen Oxides (NOx)

11,471

40,460

15%

51,027

20%

Primary Exhaust PM2.5A

199

501

22%

701

28%

Volatile Organic Compounds (VOC)

4,438

10,366

21%

15,139

27%

Sulfur Dioxide (SO2)

147

10%

298

19%

373

23%

Carbon Monoxide (CO)

70,292

176,283

20%

252,482

25%

1,3-Butadiene

17%

34%

38%

Acetaldehyde

216

22%

326

26%

Benzene

13%

208

30%

302

36%

Formaldehyde

157

20%

258

24%

Naphthalene0

28%

33%

Ethylbenzene

128

22%

195

30%

A Note that primary exhaust PM2.5 does not include brake wear and tire wear which are a significant source of
particulate emissions. After accounting for brake wear and tire wear, the total primary PM2.5 emission reductions
would be 2 percent in 2035, 7 percent in 2045, and 9 percent in 2055.

B Naphthalene includes both gas and particle phase emissions.

We estimate the emission reductions in criteria pollutants and air toxics that would result from
the alternative are smaller than those that would result from the proposal. For example, in 2055,
we estimate the alternative would reduce NOx emissions by 20 percent, PM2.5 emissions by 28
percent, and VOC emissions by 27 percent. This is compared to the proposal's reductions of
NOx by 28 percent, PM2.5 by 39 percent, and VOC by 37 percent for the proposal. Reductions in
emissions for air toxics from the alternative range from 24 percent for formaldehyde (the
proposal's estimate is 33 percent) to 38 percent for 1,3-butadiene (the proposal's estimate is 51
percent).

4.7.2 Upstream Emission Inventory Comparison

Our estimates of the additional CO2 emissions from EGUs attributable to the alternative,
relative to the reference case, are presented below in Table 4-32 for calendar years 2035, 2045,
and 2055.

Table 4-32 Annual upstream EGU CO2 emission increases from the alternative standards in calendar years

(CYs) 2035, 2045, and 2055

Pollutant

Increase in EGU Emissions (MMT)

CY 2035

CY 2045

CY 2055

Carbon Dioxide (CO2)

In 2055, we estimate the alternative would increase EGU emissions of CO2 by 8 million
metric tons compared to 11 million metric tons from the proposal. The EGU impacts decrease
over time because of projected changes in the power generation mix.

We present the cumulative CO2 increases from EGUs that we expect would result from the
proposal and alternative, measured in billion metric tons (BMT), in Table 4-33. We expect the

358

-------
alternative would result in 0.3 billion metric tons of increased CO2 emissions from EGUs,
compared to 0.4 billion metric tons from the proposal.

Table 4-33 Cumulative 2027-2055 EGU CO2 emission increases from the proposed and alternative CO2

emission standards

Pollutant

EGU CO2 emissions increase (BMT)

Proposal

Alternative

Carbon Dioxide (CO2)

0.4

0.3

Table 4-34 contains our estimates of EGU emission increases from the alternative for some
criteria pollutants.

Table 4-34 Annual upstream EGU criteria pollutant emission increases from the alternative in calendar years

(CYs) 2035, 2045, and 2055

Pollutant

Increase in EGU Emissions (U.S. Tons)

CY 2035

CY 2045

CY 2055

Nitrogen Oxides (NOx)

2,054

1,625

575

Primary PM2.5

885

761

549

Volatile Organic Compounds (VOC)

458

563

551

Sulfur Dioxide (SO2)

7,235

1,863

666

In 2055, we estimate the alternative would increase EGU emissions of NOx by 575 tons,
PM2.5 by 549 tons, VOC by 551 tons, and SO2 by 666 tons. In general, we expect the EGU
emissions increases from the alternative to be 20 to 30 percent smaller than for the proposal
because of the slower adoption of HD ZEVs.

The projected impacts on refinery emissions in 2055 for the alternative are presented in Table
4-35. The emission reductions for refineries are 20 to 30 percent smaller than the proposal.

Table 4-35 Emission reductions from refineries in CY 2055 from the proposal and alternative

Pollutant

CY 2055 Refinery Emission Reductions
(U.S. Tons)

Proposal

Alternative

NOx

1,785

1,298

PM2.5

436

318

VOC

1,227

894

S02

642

468

4.7.3 Net Emission Inventory Comparison

We expect the alternative will have lower downstream emission reductions than the proposal,
but we expect that it will also have smaller increases in EGU emissions when compared to the
proposal.

Table 4-36 shows a summary of our modeled downstream, upstream, and net CO2 emission
impacts of the alternative relative to the reference case (i.e., the inventory without the proposed
standards), in million metric tons, for calendar years 2035, 2045, and 2055.

359

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Table 4-36 Annual net CO2 emission impacts3 from the alternative in calendar years (CYs) 2035, 2045, and

2055

Pollutant

CY 2035 Impacts (MMT)

CY 2045 Im

pacts (MMT)

CY 2055 Impacts (MMT)

Downstream

EGU

Net

Downstream

EGU

Net

Downstream

EGU

Net

C02

-36

-22

-73

-62

-90

-82

a We present emissions reductions as negative numbers and emission increases as positive numbers.

In 2055, we estimate the alternative would result in a net decrease of 82 million metric tons in
CO2 emissions. The estimated net reduction for the proposal is 114 million metric tons. The net
decreases are projected to become larger between 2035 and 2055 as we expect that the HD fleet
turns over and the power generation mix shifts.

Table 4-37 presents the cumulative net CO2 emissions impact that we expect would result
from the proposed standards and the alternative, measured in billion metric tons (BMT). Overall,
we expect downstream reduction in CO2 emissions to be far larger than upstream increases from
EGUs for both the proposal and alternative. We expect the alternative would result in a net
reduction of 1.3 billion metric tons from 2027 to 2055, about 28% less than the 1.8 billion metric
tons of cumulative CO2 emissions reductions we expect from the proposal.

Table 4-37 Cumulative 2027-2055 EGU CO2 emission impacts3 from the alternative compared to the

proposed standards

Pollutant

Proposal

Alterative

Downstream

EGU

Net

Downstream

EGU

Net

Carbon Dioxide (CO2)

-2.2

0.4

1.8

-1.6

0.3

1.3

a We present emissions reductions as negative numbers and emission increases as positive numbers.

Table 4-38 contains a summary of the modeled net impacts of the alternative on criteria
pollutant emissions considering downstream and EGUs, relative to the reference case, for
calendar years 2035 and 2045. Table 4-39 contains a similar summary for calendar year 2055
that includes estimates of net impacts of refinery, EGU, and downstream emissions.

Table 4-38 Annual net impacts3 on criteria pollutant emissions from the alternative in calendar years (CYs)

2035 and 2045

Pollutant

CY 2035 Impacts (U.S. Tons)

CY 2045 Impacts (U.S. Tons)

Downstream

EGU

Net

Downstream

EGU

Net

NOx

-11,471

2,054

-9,417

-40,460

1,625

-38,836

PM2.5

-199

885

687

-501

761

260

VOC

-4,438

458

-3,980

-10,366

563

-9,802

S02

-147

7,235

7,088

-298

1,863

1,565

a We present emissions reductions as negative numbers and emission increases as positive
numbers.

Table 4-39 Net impacts3 on criteria pollutant emissions from the alternative in CY 2055

Pollutant

CY 2055 Impacts (U.S. Tons)

Downstream

EGU

Refinery

Net

NOx

-51,027

575

-1,298

-51,750

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PM-s

-701

549

-318

-471

VOC

-15.139

551

-894

-15,482

SO;;

-373

666

-468

-175

a We present emissions reductions as negative numbers and emission
increases as positive numbers.

Finally, Figure 4-22 shows the net year-over-year CO2 emissions impacts for the proposal and
alternative. Consistent with the lower HD ZEV adoption, the alternative results in lower net
reductions of CO2 than the proposal, by 25 percent to 30 percent depending on the calendar year.

2030

2040
Calendar Year

2050

— Alternative — Proposal

Figure 4-22 Comparison of net C02 emission impacts of the proposal and alternative from 2027 through 2055

Appendix A to Chapter 4- Updates to MQVES3.R3 for light-duty vehicles

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The base energy rates for electric passenger cars in MOVES3.R3 have been significantly
updated from MOVES3. To develop these rates, nine LD BEVs representative of the 2019 fleet
were modeled in EPA's Advanced Light-Duty Powertrain and Hybrid Analysis (ALPHA)
model37 and averaged according to 2019 sales estimates. More detail on the derivation of
passenger car BEV rates can be found in the GHG and Energy Consumption technical report.7

There is not enough information available on the market or in EPA's test car list to properly
represent LD electric trucks and all LHD2b3 vehicles in ALPHA. Therefore, rates for LD
electric trucks and LHD2b3 BEVs were scaled from the BEV passenger car rates assuming that
energy gained from regenerative braking and energy used during all other operation increase
linearly with vehicle mass.

In MOVES3.R3 national defaults, the population of electric LD cars and trucks of MYs 2020
and later are modeled with market shares from the Revised 2023 and Later Model Year Light-
Duty Vehicle Greenhouse Gas Emissions Standards (LD GHG 2023-2026) final rule.29 The
market shares for other fuel types were proportionally reduced so that the total market share for
all fuel types sums to 100%. In the MOVES defaults, all electric LD cars are modeled as
regulatory class 20 and engine technology 30 (battery electric vehicles), and all electric LD
trucks are modeled as regulatory class 30 and engine technology 30.

We estimated adoption rates of BEV Class 2b and 3 vehicles (MOVES regulatory class 41)
using the same methodology and sources in Chapter 4.3.1, describing the reference case adoption
of HD ZEVs. The following table shows California's ACT sales volumes for Classes 2b and 3
and the national ZEV adoption used for modeling the reference case. We did not alter the
adoption of ZEVs for these vehicle types in the control cases.

Class 2b-3 Group

Model Year

CA ACT

Reference Case

ZEV Sales

National ZEV Sales

2024

0.5%

2025

1.0%

2026

10%

1.5%

2027

15%

2.2%

2028

20%

3.0%

2029

25%

3.9%

2030

30%

4.7%

2031

35%

5.6%

2032

40%

6.4%

2033

45%

7.3%

2034

50%

8.1%

2035

55%

9.0%

2036 and beyond

55%

9.3%

Energy consumption rates for LD ICE vehicles were also updated in MOVES3.R3 to account
for the LD GHG 2023-2026 final rule. The real-world CO2 values estimated in the rulemaking
were used as input to update MOVES3.R3, and the real-world CO2 calculation used CO2 2-cycle
g/mile rates, off-cycle credits, and air conditioning system efficiency credits.

Adjustment ratios based on real-world CO2 values estimated in the LD GHG 2023-2026 final
rule were applied directly to both running and start energy rates in MOVES for all LD vehicles

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(regulatory classes 20 and 30). Those adjustment ratios vary by model year for MYs 2020
through 2060.

Some vehicle emission regulations, including the LD GHG 2023-2026 rule, allow
manufacturers to meet emission targets through what are known as "averaging, banking and
trading" provisions. These provisions allow higher emissions from some vehicles in return for
lower emissions from others. In general, MOVES does not account for these details because
MOVES is designed to estimate emissions of "fleet-average" vehicles rather than individual
vehicles or vehicle families. However, MOVES3.R3 explicitly accounts for the allowed
increases in the LD ICE emission and energy consumption rates with the increase in national
BEV sales, to better capture the expected fleet-wide emission impacts of LD BEV adoption.
Details on the data sources and algorithms for this adjustment are described in the MOVES3.R3
emission adjustment technical report.38 There are no such adjustments for medium-duty or
heavy-duty vehicles.

The LD gasoline PM emission rates in MOVES were updated to account for newer data
describing the fractions of gasoline direct injection (GDI) and port fuel injection (PFI) engines in
the fleet. For MYs 2004 through 2020, the rates were based on data from the annual EPA
Automotive Trends Report.39 For MYs 2021 and later, the EPA CAFE Compliance and Effects
Modeling System (CCEMS) Post Processing Tool40 was applied to data from runs of the NHTSA
Corporate Average Fuel Economy (CAFE) model41 to extract modeled future population
fractions of GDI and PFI vehicles for both LD cars and LD trucks.

MOVES3.R3 also includes an update to the relative mileage accumulation rate of LD
vehicles, which allocates national VMT by source type and vehicle age. In general, MOVES3.R3
allocates more VMT to light-duty trucks than passenger cars and allocates more VMT to light-
duty vehicles less than 12 years old. This results in a small net increase in emission inventories.

Finally, onroad vehicle ammonia (NFb) emission rates in MOVES3.R3 were updated based
on data from remote sensing devices.42 The data and analysis supporting this update is described
more fully in the MOVES3.R3 Light-Duty Emission Rate technical report.43

Chapter 4 References

1 Murray, Evan. Memorandum to Docket EPA-HQ-OAR-2022-0985. "MOVES3.R3". February 2023.

2 U.S. EPA. (2022). Motor Vehicle Emission Simulator: MOVES3.1. Available online:
https://github.eom/USEPA/EPA_MOVES_Model/releases/tag/MOVES3.l.0. See also: https://epa.gov/moves

3 U.S. EPA. "Pre-IRA 2022 Reference Case". Power Sector Modeling. February 8, 2023. Available online:
https://www.epa.gov/power-sector-modeling/pre-ira-2022-reference-case

4 Murray, Evan. "IPM Documentation". March 2023.

5 CFRpart 86.091-2. Available online: https://www.govinfo.gov/content/pkg/CFR-1998-title40-voll2/pdf/CFR-
1998-title40-vol 12-sec86-091 -2.pdf

6 U.S. EPA. "Frequently Asked Questions about Heavy-Duty 'Glider Vehicles' and 'Glider Kits'. July 2015.
Available online: https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P 100MUVI.PDF

7 U.S. EPA. "Greenhouse Gas and Energy Consumption Rates for Onroad Vehicles in MOVES3.R3". March 2023.

8 American Automobile Association, Inc. "AAA Electric Vehicle Range Testing. AAA proprietary research into the
effect of ambient temperature and HVAC use on driving range and MPGe". American Automobile Association, Inc.

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2019. Available online: https://www.aaa.com/AAA/common/AAR/files/AAA-Electric-Vehicle-Range-Testing-
Report.pdf

9 Henning, Mark; Thomas, Andrew R.; and Smyth, Alison. "An Analysis of the Association between Changes in
Ambient Temperature, Fuel Economy, and Vehicle Range for Battery Electric and Fuel Cell Electric Buses." Urban
Publications. November 2019. Available online: https://engagedscholarship.csuohio.edu/urban_facpub/1630

10 U.S. EPA. "Emission Adjustments for Onroad Vehicles in MOVES3.R3". March 2023.

11 Ehsan Sabri Islam, Ram Vijayagopal, Aymeric Rousseau. "A Comprehensive Simulation Study to Evaluate
Future Vehicle Energy and Cost Reduction Potential", Report to the US Department of Energy, Contract ANL/ESD-
22/6, October 2022. Available online: https://anl.app.box.eom/s/qc3nov3w25qmxs20b2m2wmru0gadp83z

12 Wang, Michael, Elgowainy, Amgad, Lu, Zifeng, Baek, Kwang H., Bafana, Adarsh, Benavides, Pahola T.,
Burnham, Andrew, Cai, Hao, Cappello, Vincenzo, Chen, Peter, Gan, Yu, Gracida-Alvarez, Ulises R., Hawkins,

Troy R., Iyer, Rakesh K., Kelly, Jarod C., Kim, Taemin, Kumar, Shishir, Kwon, Hoyoung, Lee, Kyuha, Lee,

Uisung, Liu, Xinyu, Masum, Farhad, Ng, Clarence, Ou, Longwen, Reddi, Krishna, Siddique, Nazib, Sun, Pingping,
Vyawahare, Pradeep, Xu, Hui, and Zaimes, George. Greenhouse gases, Regulated Emissions, and Energy use in
Technologies Model ® (2022 .Net). Computer Software. USDOE Office of Energy Efficiency and Renewable
Energy (EERE). 10 Oct. 2022. Web. doi:10.11578/GREET-Net-2022/dc.20220908.2

13 Sandhu, Gurdas; Sonntag, Darrell; Sanchez, James. 2018. Identifying Areas of High NOx Operation in Heavy -
Duty Vehicles, 28th CRC Real-World Emissions Workshop, March 18-21, 2018, Garden Grove, California, USA

14 Quiros, D. C., A. Thiruvengadam, S. Pradhan, M. Besch, P. Thiruvengadam, B. Demirgok, D. Carder, A.
Oshinuga, T. Huai and S. Hu (2016). Real-World Emissions from Modern Heavy-Duty Diesel, Natural Gas, and
Hybrid Diesel Trucks Operating Along Major California Freight Corridors. Emission Control Science and
Technology, 2 (3), 156-172. DOI: 10.1007/s40825-016-0044-0.

15 H. C. Frey and P. Y. Kuo. "Real-World Energy Use and Emission Rates for Idling Long-Haul Trucks and Selected
Idle Reduction Technologies". Journal of the Air & Waste Management Association. January 24, 2012. Available
online: https://doi.Org/10.3155/1047-3289.59.7.857

16 U.S. EPA. "Population and Activity of Onroad Vehicles in MOVES3.R3". March 2023.

17 U.S. EPA. "Exhaust Emission Rates for Heavy-Duty Onroad Vehicles in MOVES3.R3". March 2023.

18 88 FR 4296, March 27, 2023.

19 Preble, C. V., R. A. Harley and T. W. Kirchstetter (2019). Control Technology-Driven Changes to In-Use Heavy-
Duty Diesel Truck Emissions of Nitrogenous Species and Related Environmental Impacts. Environ Sci Technol, 53
(24), 14568-14576. DOI: 10.1021/acs.est.9b04763.

20 Khalek, Imad, Thomas L Bougher and Patrick M. Merritt. "Phase 1 of the Advanced Collaborative Emissions
Study (ACES)". Southwest Research Institute, Coordinating Research Council, Health Effects Institute. June 15,
2009.

21 U.S. Energy Information Administration (EIA). "Annual Energy Outlook 2022". U.S. Department of Energy.
March 3, 2022. Available online: https://www.eia.gov/outlooks/aeo/

22 US Federal Highway Administration (FHWA). Office of Highway Policy Information (OHPI). "Table VM-1,

State Motor-Vehicle Registrations". U.S. Department of Transportation. November 2021. Available online:
https://www.fhwa.dot.gov/policyinformation/statistics/2020/pdf/vml.pdf

23 Davis, S., and Boundy, R. "Transportation Energy Data Book: Edition 40". Oak Ridge National Laboratory
(ORNL), Center for Transportation Analysis. June 2022. Available online: https://tedb.ornl.gov/wp-
content/uploads/2022/03/TEDB_Ed_40.pdf

24 Bobit Publications. "School Bus Fleet Fact Book". 2021. Available online: http://www.schoolbusfleet.com
25IHS, Inc. (formerly R.L. Polk & Co.). "National Vehicle Population Profile", Southfield, MI; 2020;

http s: //www. ihs. com/btp/polk. html

26 Murray, Evan. Memorandum to Docket EPA-HQ-OAR-2022-0985. "MOVES Inputs and Post-Processing
Materials". March 2023.

27 "Text - H.R.5376 - 117th Congress (2021-2022): Inflation Reduction Act of 2022." Congress.gov, Library of
Congress, 16 August 2022, https://www.congress.gOv/bill/l 17th-congress/house-bill/5376/text

28 U.S. Energy Information Administration (EIA). "Annual Energy Outlook 2021". U.S. Department of Energy.
February 3, 2021. Available online: https://www.eia.gov/outlooks/archive/aeo21/

29 86 FR 74434. December 30, 2021.

30 U.S. Department of Energy. "Pathways to Commercial Liftoff: Clean Hydrogen". March 2023. Available online:
https://liftoff.energy.gOv/wp-content/uploads/2023/03/20230320-Liftoff-Clean-H2-vPUB.pdf.

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31 National Renewable Energy Laboratory (NREL). "H2A: Hydrogen Analysis Production Model: Version 3.2018".
Available online: https://www.nrel.gov/hydrogen/h2a-production-archive.html

32 NREL. "Electric Vehicle Infrastructure Projection Tool (EVI-Pro) Lite. Available online:
http s: //afdc. energy. gov/evi -pro -lite

33 U.S. EPA. "2016v2 Platform". January 23, 2023. Available online: https://www.epa.gov/air-emissions-
modeling/2016v2-platform

34 Zawacki, M. Memorandum to Docket EPA-HQ-OAR-2022-0985. "Estimating Refinery Emission Impacts for
HDP3 NPRM" February 2023.

35 U.S. EPA (2022) Preparation of Emissions Inventories for 2016v2 North American Emissions Modeling Platform
Technical Support Document. Available online: https://www.epa.gov/air-emissions-modeling/2016-version-2-
technical-support-document.

36 The Intergovernmental Panel on Climate Change, Climate Change 2007: Impacts, Adaptation and Vulnerability.
https://www.ipcc.ch/site/assets/uploads/2018/03/ar4_wg2_full_report.pdf

37 U.S. EPA. "Advanced Light-Duty Powertrain and Hybrid Analysis (ALPHA) Tool". Office of Transportation and
Air Quality. US Environmental Protection Agency. December 2020. Available online:

https://www.epa.gov/regulations-emissions-vehicles-and-engines/advanced-light-duty-powertrain-and-hybrid-
analysis-alpha#overview

38 U.S. EPA. "Emission Adjustments for Onroad Vehicles in MOVES3.R3". March 2023.

39 U.S. EPA. "The 2020 EPA Automotive Trends Report: Greenhouse Gas Emissions, Fuel Economy, and
Technology since 1975". U.S. EPA. January 2021.

40 U.S. EPA. Memorandum to Docket EPA-HQ-OAR-2021-0208. "EPA CCEMS Post Processing Tool - Release
0.3.1". July 21, 2021. Docket ID EPA-HQ-OAR-2021-0208-0133.

41 National Highway Traffic Safety Administration (NHTSA). "Corporate Average Fuel Economy (CAFE) model".
U.S. Department of Transportation. January 20, 2022. Available online: https://www.nhtsa.gov/corporate-average-
fuel-economy/cafe-compliance-and-effects-modeling-system

42 G. A. Bishop and D. H. Stedman. "Reactive Nitrogen Species Emission Trends in Three Light-/Medium United
States Fleets". Environmental Science and Technology. August 21, 2015. Available online:
https://doi.org/10.1021/acs.est. 5b023 92

43U.S. EPA. "Exhaust Emission Rates for Light-Duty Onroad Vehicles in MO VES3.R1". February 2023.

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Chapter 5 Health and Environmental Impacts

5.1 Climate Change Impacts

Elevated concentrations of GHGs have been warming the planet, leading to changes in the
Earth's climate including changes in the frequency and intensity of heat waves, precipitation, and
extreme weather events; rising seas; and retreating snow and ice. The changes taking place in the
atmosphere as a result of the well-documented buildup of GHGs due to human activities are
changing the climate at a pace and in a way that threatens human health, society, and the natural
environment. While EPA is not making any new scientific or factual findings with regard to the
well-documented impact of GHG emissions on public health and welfare in support of this rule,
EPA is providing some scientific background on climate change to offer additional context for
this rulemaking and to increase the public's understanding of the environmental impacts of
GHGs.

Extensive information on climate change impacts is available in the scientific assessments
that are briefly described in this section, as well as in the technical and scientific information
supporting them. One of those documents is the EPA's 2009 Endangerment and Cause or
Contribute Findings for GHGs Under section 202(a) of the CAA (74 FR 66496; December 15,
2009).1 In the 2009 Endangerment Findings, the Administrator found under section 202(a) of the
CAA that elevated atmospheric concentrations of six key well-mixed GHGs—CO2, CH4, N2O,
hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SFr>)—"may
reasonably be anticipated to endanger the public health and welfare of current and future
generations" (74 FR 66523; December 15, 2009), and the science and observed changes have
confirmed and strengthened the understanding and concerns regarding the climate risks
considered in the Finding. The 2009 Endangerment Findings, together with the extensive
scientific and technical evidence in the supporting record, documented that climate change
caused by human emissions of GHGs threatens the public health of the U.S. population.

The most recent information demonstrates that the climate is continuing to change in response
to the human-induced buildup of GHGs in the atmosphere. Recent scientific assessments show
that atmospheric concentrations of GHGs have risen to a level that has no precedent in human
history and that they continue to climb, primarily because of both historic and current
anthropogenic emissions, and that these elevated concentrations endanger our health by affecting
our food and water sources, the air we breathe, the weather we experience, and our interactions
with the natural and built environments.

Global average temperature has increased by about 1.1 degrees Celsius (°C) (2.0 degrees
Fahrenheit (°F)) in the 2011-2020 decade relative to 1850-1900.1 The IPCC determined with
medium confidence that this past decade was warmer than any multi-century period in at least
the past 100,000 years.2 Global average sea level has risen by about 8 inches (about 21
centimeters (cm)) from 1901 to 2018, with the rate from 2006 to 2018 (0.15 inches/year or 3.7
millimeters (mm)/year) almost twice the rate over the 1971 to 2006 period, and three times the
rate of the 1901 to 2018 period.3 The rate of sea level rise during the 20th Century was higher
than in any other century in at least the last 2,800 years.4 The CO2 being absorbed by the ocean

1 In describing these 2009 Findings in this proposal, the EPA is neither reopening nor revisiting them.

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has resulted in changes in ocean chemistry due to acidification of a magnitude not seen in 65
million years,5 putting many marine species—particularly calcifying species—at risk. Human-
induced climate change has led to heatwaves and heavy precipitation becoming more frequent
and more intense, along with increases in agricultural and ecological droughts11 in many regions.6
The NCA4 found that it is very likely (greater than 90 percent likelihood) that by mid-century,
the Arctic Ocean will be almost entirely free of sea ice by late summer for the first time in about
2 million years.7 Coral reefs will be at risk for almost complete (99 percent) losses with 1 °C
(1.8 °F) of additional warming from today (2 °C or 3.6 °F since preindustrial). At this
temperature, between 8 and 18 percent of animal, plant, and insect species could lose over half of
the geographic area with suitable climate for their survival, and 7 to 10 percent of rangeland
livestock would be projected to be lost.8 The IPCC similarly found that climate change has
caused substantial damages and increasingly irreversible losses in terrestrial, freshwater, and
coastal and open ocean marine ecosystems.9

Scientific assessments also demonstrate that even modest additional amounts of warming may
lead to a climate different from anything humans have ever experienced. Every additional
increment of temperature comes with consequences. For example, the half-degree of warming
from 1.5 to 2 °C (0.9 °F of warming from 2.7 °F to 3.6 °F) above preindustrial temperatures is
projected on a global scale to expose 420 million more people to frequent extreme heatwaves,
and 62 million more people to frequent exceptional heatwaves (where heatwaves are defined
based on a heat wave magnitude index which takes into account duration and intensity—using
this index, the 2003 French heat wave that led to almost 15,000 deaths would be classified as an
"extreme heatwave" and the 2010 Russian heatwave which led to thousands of deaths and
extensive wildfires would be classified as "exceptional"). Every additional degree will intensify
extreme precipitation events by about 7 percent. The peak winds of the most intense tropical
cyclones (hurricanes) are projected to increase with warming. In addition to a higher intensity,
the IPCC found that precipitation and frequency of rapid intensification of these storms has
already increased, while the movement speed has decreased, and elevated sea levels have
increased coastal flooding, all of which make these tropical cyclones more damaging.10

The NCA4 recognized that climate change can increase risks to national security, both
through direct impacts on military infrastructure, but also by affecting factors such as food and
water availability that can exacerbate conflict outside U.S. borders. Droughts, floods, storm
surges, wildfires, and other extreme events stress nations and people through loss of life,
displacement of populations, and impacts on livelihoods.11 Risks to food security would increase
from "medium" to "high" for several lower income regions in the Sahel, southern Africa, the
Mediterranean, central Europe, and the Amazon. In addition to food security issues, this
temperature increase would have implications for human health in terms of increasing ozone
pollution, heatwaves, and vector-borne diseases (for example, expanding the range of the
mosquitoes which carry dengue fever, chikungunya, yellow fever, and the Zika virus; or the ticks
that carry Lyme disease or Rocky Mountain Spotted Fever).12

The NCA4 also evaluated a number of impacts specific to the U.S. Severe drought and
outbreaks of insects like the mountain pine beetle have killed hundreds of millions of trees in the
western U.S. Wildfires have burned more than 3.7 million acres in 14 of the 17 years between
2000 and 2016, and Federal wildfire suppression costs were about a billion dollars annually.13

11 These are drought measures based on soil moisture.

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The National Interagency Fire Center has documented U.S. wildfires since 1983; the 10 years
with the largest acreage burned have all occurred since 2004.14 Wildfire smoke degrades air
quality, increasing health risks. More frequent and severe wildfires due to climate change would
further diminish air quality, increase incidences of respiratory illness, impair visibility, and
disrupt outdoor activities, sometimes thousands of miles from the location of the fire.15

While GHGs collectively are not the only factor that controls climate, it is illustrative that 3
million years ago (the last time CO2 concentrations were this high) Greenland was not yet
completely covered by ice and still supported forests, while 23 million years ago (the last time
concentrations were above 450 ppm) the West Antarctic ice sheet was not yet developed,
indicating the possibility that high GHG concentrations could lead to a world that looks very
different from today and from the conditions in which human civilization has developed. If the
Greenland and Antarctic ice sheets were to melt substantially, sea levels would rise
dramatically—the IPCC estimated that during the next 2,000 years, sea level will rise by 7 to 10
feet even if warming is limited to 1.5 °C (2.7 °F), from 7 to 20 feet if limited to 2 °C (3.6 °F), and
by 60 to 70 feet if warming is allowed to reach 5 °C (9 °F) above preindustrial levels.16 For
context, almost all of the city of Miami is less than 25 feet above sea level, and the NCA4 stated
that 13 million Americans would be at risk of migration due to 6 feet of sea level rise.

Meanwhile, sea level rise has amplified coastal flooding and erosion impacts, requiring the
installation of costly pump stations, flooding streets, and increasing storm surge damages. Tens
of billions of dollars of U.S. real estate could be below sea level by 2050 under some scenarios.
Increased frequency and duration of drought will reduce agricultural productivity in some
regions, accelerate depletion of water supplies for irrigation, and expand the distribution and
incidence of pests and diseases for crops and livestock.

5.2 Health Effects Associated with Exposure to Non-GHG Pollutants

Heavy duty vehicles emit non-GHG pollutants that contribute to ambient concentrations of
ozone, PM, NO2, SO2, CO, and air toxics. As described in draft RIA Chapter 4, the increased use
of zero-emission technology in the heavy-duty sector would reduce emissions of non-GHG
pollutants from heavy-duty vehicles. A discussion of the health effects associated with exposure
to these pollutants is presented in this section of the RIA. The following discussion of health
impacts is mainly focused on describing the effects of air pollution on the population in general.

Additionally, because children have increased vulnerability and susceptibility for adverse
health effects related to air pollution exposures, EPA's findings regarding adverse effects for
children related to exposure to pollutants that are impacted by this rule are noted in this section.
The increased vulnerability and susceptibility of children to air pollution exposures may arise
because infants and children generally breathe more relative to their size than adults, and
consequently they may be exposed to relatively higher amounts of air pollution.17 Children also
tend to breathe through their mouths more than adults, and their nasal passages are less effective
at removing pollutants which leads to greater lung deposition of some pollutants, such as PM.18'19
Furthermore, air pollutants may pose health risks specific to children because children's bodies
are still developing.111 For example, during periods of rapid growth such as fetal development,
infancy and puberty, their developing systems and organs may be more easily harmed.20'21 EPA

111 Children's environmental health includes conception, infancy, early childhood and through adolescence until 21
years of age as described in the EPA Memorandum: Issuance of EPA's 2021 Policy on Children's Health. October
5, 2021. Available at https://www.epa.gov/system/files/documents/2021-10/2021-policy-on-childrens-health.pdf.

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produces the report titled "America's Children and the Environment," which presents national
trends on air pollution and other contaminants and environmental health of children.22

5.2.1 Ozone

5.2.1.1 Background on Ozone

Ground-level ozone pollution forms in areas with high concentrations of ambient NOx and
VOCs when solar radiation is high. Major U.S. sources of NOx are highway and nonroad motor
vehicles and engines, power plants, and other industrial sources, with natural sources, such as
soil, vegetation, and lightning, serving as smaller sources. Vegetation is the dominant source of
VOCs in the U.S. Volatile consumer and commercial products, such as propellants and solvents,
highway and nonroad vehicles, engines, fires, and industrial sources also contribute to the
atmospheric burden of VOCs at ground-level.

The processes underlying ozone formation, transport, and accumulation are complex.
Ground-level ozone is produced and destroyed by an interwoven network of free radical
reactions involving the hydroxyl radical (OH), NO, NO2, and complex reaction intermediates
derived from VOCs. Many of these reactions are sensitive to temperature and available sunlight.
High ozone events most often occur when ambient temperatures and sunlight intensities remain
high for several days under stagnant conditions. Ozone and its precursors can also be transported
hundreds of miles downwind, which can lead to elevated ozone levels in areas with otherwise
low VOC or NOx emissions. As an air mass moves and is exposed to changing ambient
concentrations of NOx and VOCs, the ozone photochemical regime (relative sensitivity of ozone
formation to NOx and VOC emissions) can change.

When ambient VOC concentrations are high, comparatively small amounts of NOx catalyze
rapid ozone formation. Without available NOx, ground-level ozone production is severely
limited, and VOC reductions would have little impact on ozone concentrations. Photochemistry
under these conditions is said to be "NOx-limited." When NOx levels are sufficiently high, faster
NO2 oxidation consumes more radicals, dampening ozone production. Under these "VOC-
limited" conditions (also referred to as "NOx-saturated" conditions), VOC reductions are
effective in reducing ozone, and NOx can react directly with ozone resulting in suppressed ozone
concentrations near NOx emission sources. Under these NOx-saturated conditions, NOx
reductions can actually increase local ozone under certain circumstances, but overall ozone
production (considering downwind formation) decreases and even in VOC-limited areas, NOx
reductions are not expected to increase ozone levels if the NOx reductions are sufficiently large -
large enough for photochemistry to become NOx-limited.

5.2.1.2 Health Effects Associated with Exposure to Ozone

This section provides a summary of the health effects associated with exposure to ambient
concentrations of ozone.1V The information in this section is based on the information and
conclusions in the April 2020 Integrated Science Assessment for Ozone (Ozone ISA).23 The
Ozone ISA concludes that human exposures to ambient concentrations of ozone are associated
with a number of adverse health effects and characterizes the weight of evidence for these health

lv Human exposure to ozone varies over time due to changes in ambient ozone concentration and because people
move between locations which have notable different ozone concentrations. Also, the amount of ozone delivered to
the lung is not only influenced by the ambient concentrations but also by the breathing route and rate.

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effects.v The discussion below highlights the Ozone ISA's conclusions pertaining to health
effects associated with both short-term and long-term periods of exposure to ozone.

For short-term exposure to ozone, the Ozone ISA concludes that respiratory effects, including
lung function decrements, pulmonary inflammation, exacerbation of asthma, respiratory-related
hospital admissions, and mortality, are causally associated with ozone exposure. It also
concludes that metabolic effects, including metabolic syndrome (i.e., changes in insulin or
glucose levels, cholesterol levels, obesity and blood pressure) and complications due to diabetes
are likely to be causally associated with short-term exposure to ozone, and that evidence is
suggestive of a causal relationship between cardiovascular effects, central nervous system effects
and total mortality and short-term exposure to ozone.

For long-term exposure to ozone, the Ozone ISA concludes that respiratory effects, including
new onset asthma, pulmonary inflammation and injury, are likely to be causally related with
ozone exposure. The Ozone ISA characterizes the evidence as suggestive of a causal relationship
for associations between long-term ozone exposure and cardiovascular effects, metabolic effects,
reproductive and developmental effects, central nervous system effects and total mortality. The
evidence is inadequate to infer a causal relationship between chronic ozone exposure and
increased risk of cancer.

Finally, interindividual variation in human responses to ozone exposure can result in some
groups being at increased risk for detrimental effects in response to exposure. In addition, some
groups are at increased risk of exposure due to their activities, such as outdoor workers and
children. The Ozone ISA identified several groups that are at increased risk for ozone-related
health effects. These groups are people with asthma, children and older adults, individuals with
reduced intake of certain nutrients (i.e., Vitamins C and E), outdoor workers, and individuals
having certain genetic variants related to oxidative metabolism or inflammation. Ozone exposure
during childhood can have lasting effects through adulthood. Such effects include altered
function of the respiratory and immune systems. Children absorb higher doses (normalized to
lung surface area) of ambient ozone, compared to adults, due to their increased time spent
outdoors, higher ventilation rates relative to body size, and a tendency to breathe a greater
fraction of air through the mouth.V1 Children also have a higher asthma prevalence compared to
adults. Recent epidemiologic studies provide generally consistent evidence that long-term ozone
exposure is associated with the development of asthma in children. Studies comparing age
groups reported higher magnitude associations for short-term ozone exposure and respiratory
hospital admissions and emergency room visits among children than for adults. Panel studies

v The ISA evaluates evidence and draws conclusions on the causal relationship between relevant pollutant exposures
and health effects, assigning one of five "weight of evidence" determinations: causal relationship, likely to be a
causal relationship, suggestive of a causal relationship, inadequate to infer a causal relationship, and not likely to be
a causal relationship. For more information on these levels of evidence, please refer to Table II in the Preamble of
the ISA.

V1 Children are more susceptible than adults to many air pollutants because of differences in physiology, higher per
body weight breathing rates and consumption, rapid development of the brain and bodily systems, and behaviors
that increase chances for exposure. Even before birth, the developing fetus may be exposed to air pollutants through
the mother that affect development and permanently harm the individual.

Infants and children breathe at much higher rates per body weight than adults, with infants under one year of age
having a breathing rate up to five times that of adults. In addition, children breathe through their mouths more than
adults and their nasal passages are less effective at removing pollutants, which leads to a higher deposition fraction
in their lungs.

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also provide support for experimental studies with consistent associations between short-term
ozone exposure and lung function and pulmonary inflammation in healthy children. Additional
children's vulnerability and susceptibility factors are listed above in Chapter 5.2.

5.2.2 Particulate Matter

5.2.2.1 Background on Particulate Matter

Particulate matter (PM) is a complex mixture of solid particles and liquid droplets distributed
among numerous atmospheric gases which interact with solid and liquid phases. Particles in the
atmosphere range in size from less than 0.01 to more than 10 micrometers (|im) in diameter.24
Atmospheric particles can be grouped into several classes according to their aerodynamic
diameter and physical sizes. Generally, the three broad classes of particles include ultrafine
particles (UFPs, generally considered as particles with a diameter less than or equal to 0.1 |im
[typically based on physical size, thermal diffusivity or electrical mobility]), "fine" particles
(PM2.5; particles with a nominal mean aerodynamic diameter less than or equal to 2.5 |im), and
"thoracic" particles (PM10; particles with a nominal mean aerodynamic diameter less than or
equal to 10 |im). Particles that fall within the size range between PM2.5 and PM10, are referred to
as "thoracic coarse particles" (PM10-2.5, particles with a nominal mean aerodynamic diameter
greater than 2.5 |im and less than or equal to 10 |im). EPA currently has standards that regulate
PM2.5 and PMio.vii

Most particles are found in the lower troposphere, where they can have residence times
ranging from a few hours to weeks. Particles are removed from the atmosphere by wet
deposition, such as when they are carried by rain or snow, or by dry deposition, when particles
settle out of suspension due to gravity. Atmospheric lifetimes are generally longest for PM2.5,
which often remains in the atmosphere for days to weeks before being removed by wet or dry
deposition.25 In contrast, atmospheric lifetimes for UFP and PM10-2.5 are shorter. Within hours,
UFP can undergo coagulation and condensation that lead to formation of larger particles in the
accumulation mode or can be removed from the atmosphere by evaporation, deposition, or
reactions with other atmospheric components. PM10-2.5 are also generally removed from the
atmosphere within hours, through wet or dry deposition.26

Particulate matter consists of both primary and secondary particles. Primary particles are
emitted directly from sources, such as combustion-related activities (e.g., industrial activities,
motor vehicle operation, biomass burning), while secondary particles are formed through
atmospheric chemical reactions of gaseous precursors (e.g., sulfur oxides (SOx), nitrogen oxides
(NOx) and volatile organic compounds (VOCs)).

5.2.2.2 Health Effects Associated with Exposure to Particulate Matter

Scientific evidence spanning animal toxicological, controlled human exposure, and
epidemiologic studies shows that exposure to ambient PM is associated with a broad range of
health effects. These health effects are discussed in detail in the Integrated Science Assessment
for Particulate Matter, which was finalized in December 2019 (2019 PM ISA), with a more

vn Regulatory definitions of PM size fractions, and information on reference and equivalent methods for measuring
PM in ambient air, are provided in 40 CFR Parts 50, 53, and 58. With regard to national ambient air quality
standards (NAAQS) which provide protection against health and welfare effects, the 24-hour PM10 standard
provides protection against effects associated with short-term exposure to thoracic coarse particles (i.e., PMio-is)-

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targeted evaluation of studies published since the literature cutoff date of the 2019 PM ISA in the
Supplement to the Integrated Science Assessment for PM (Supplement).27'28 The PM ISA
characterizes the causal nature of relationships between PM exposure and broad health categories
(e.g., cardiovascular effects, respiratory effects, etc.) using a weight-of-evidence approach/111
Within this characterization, the PM ISA summarizes the health effects evidence for short-term
(i.e., hours up to one month) and long-term (i.e., one month to years) exposures to PM2.5, PM10-
2.5, and ultrafine particles and concludes that exposures to ambient PM2.5 are associated with a
number of adverse health effects. The discussion below highlights the PM ISA's conclusions and
summarizes additional information from the Supplement where appropriate, pertaining to the
health effects evidence for both short- and long-term PM exposures. Further discussion of PM-
related health effects can also be found in the 2022 Policy Assessment for the review of the PM
NAAQS.29

EPA has concluded that recent evidence in combination with evidence evaluated in the 2009
PM ISA supports a "causal relationship" between both long- and short-term exposures to PM2.5
and premature mortality and cardiovascular effects and a "likely to be causal relationship"
between long- and short-term PM2.5 exposures and respiratory effects.30 Additionally, recent
experimental and epidemiologic studies provide evidence supporting a "likely to be causal
relationship" between long-term PM2.5 exposure and nervous system effects and between long-
term PM2.5 exposure and cancer. Because of remaining uncertainties and limitations in the
evidence base, EPA determined the evidence is "suggestive of, but not sufficient to infer, a
causal relationship" for long-term PM2.5 exposure and reproductive and developmental effects
(i.e., male/female reproduction and fertility; pregnancy and birth outcomes), long- and short-term
exposures and metabolic effects, and short-term exposure and nervous system effects.

As discussed extensively in the 2019 PM ISA and the Supplement, recent studies continue to
support a "causal relationship" between short- and long-term PM2.5 exposures and mortality.31'32
For short-term PM2.5 exposure, multi-city studies,, in combination with single- and multi-city
studies evaluated in the 2009 PM ISA, provide evidence of consistent, positive associations
across studies conducted in different geographic locations, populations with different
demographic characteristics, and studies using different exposure assignment techniques.
Additionally, the consistent and coherent evidence across scientific disciplines for cardiovascular
morbidity, particularly ischemic events and heart failure, and to a lesser degree for respiratory
morbidity, including exacerbations of chronic obstructive pulmonary disease (COPD) and
asthma, provide biological plausibility for cause-specific mortality and ultimately total mortality.
Recent epidemiologic studies evaluated in the Supplement, including studies that employed

vm The causal framework draws upon the assessment and integration of evidence from across scientific disciplines,
spanning atmospheric chemistry, exposure, dosimetry and health effects studies (i.e., epidemiologic, controlled
human exposure, and animal toxicological studies), and assess the related uncertainties and limitations that
ultimately influence our understanding of the evidence. This framework employs a five-level hierarchy that
classifies the overall weight-of-evidence with respect to the causal nature of relationships between criteria pollutant
exposures and health and welfare effects using the following categorizations: causal relationship; likely to be causal
relationship; suggestive of, but not sufficient to infer, a causal relationship; inadequate to infer the presence or
absence of a causal relationship; and not likely to be a causal relationship (U.S. EPA. (2019). Integrated Science
Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC,
EPA/600/R-19/188, Section P. 3.2.3).

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alternative methods for confounder control, provide additional support to the evidence base that
contributed to the 2019 PM ISA conclusion for short-term PM2.5 exposure and mortality.

The 2019 PM ISA concluded a "causal relationship" between long-term PM2.5 exposure and
mortality. In addition to reanalyses and extensions of the American Cancer Society (ACS) and
Harvard Six Cities (HSC) cohorts, multiple new cohort studies conducted in the U.S. and
Canada, consisting of people employed in a specific job (e.g., teacher, nurse) and that apply
different exposure assignment techniques, provide evidence of positive associations between
long-term PM2.5 exposure and mortality. Biological plausibility for mortality due to long-term
PM2.5 exposure is provided by the coherence of effects across scientific disciplines for
cardiovascular morbidity, particularly for coronary heart disease, stroke and atherosclerosis, and
for respiratory morbidity, particularly for the development of COPD. Additionally, recent studies
provide evidence indicating that as long-term PM2.5 concentrations decrease there is an increase
in life expectancy. Recent cohort studies evaluated in the Supplement, as well as epidemiologic
studies that conducted accountability analyses or employed alternative methods for confounder
controls, support and extend the evidence base that contributed to the 2019 PM ISA conclusion
for long-term PM2.5 exposure and mortality.

A large body of studies examining both short- and long-term PM2.5 exposure and
cardiovascular effects builds on the evidence base evaluated in the 2009 PM ISA. The strongest
evidence for cardiovascular effects in response to short-term PM2.5 exposures is for ischemic
heart disease and heart failure. The evidence for short-term PM2.5 exposure and cardiovascular
effects is coherent across scientific disciplines and supports a continuum of effects ranging from
subtle changes in indicators of cardiovascular health to serious clinical events, such as increased
emergency department visits and hospital admissions due to cardiovascular disease and
cardiovascular mortality. For long-term PM2.5 exposure, there is strong and consistent
epidemiologic evidence of a relationship with cardiovascular mortality. This evidence is
supported by epidemiologic and animal toxicological studies demonstrating a range of
cardiovascular effects including coronary heart disease, stroke, impaired heart function, and
subclinical markers (e.g., coronary artery calcification, atherosclerotic plaque progression),
which collectively provide coherence and biological plausibility. Recent epidemiologic studies
evaluated in the Supplement, as well as studies that conducted accountability analyses or
employed alternative methods for confounder control, support and extend the evidence base that
contributed to the 2019 PM ISA conclusion for both short- and long-term PM2.5 exposure and
cardiovascular effects.

Studies evaluated in the 2019 PM ISA continue to provide evidence of a "likely to be causal
relationship" between both short- and long-term PM2.5 exposure and respiratory effects.
Epidemiologic studies provide consistent evidence of a relationship between short-term PM2.5
exposure and asthma exacerbation in children and COPD exacerbation in adults as indicated by
increases in emergency department visits and hospital admissions, which is supported by animal
toxicological studies indicating worsening allergic airways disease and subclinical effects related
to COPD. Epidemiologic studies also provide evidence of a relationship between short-term
PM2.5 exposure and respiratory mortality. However, there is inconsistent evidence for respiratory
effects, specifically lung function declines and pulmonary inflammation, in controlled human
exposure studies. With respect to long term PM2.5 exposure, epidemiologic studies conducted in
the U.S. and abroad provide evidence of a relationship with respiratory effects, including
consistent changes in lung function and lung function growth rate, increased asthma incidence,

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asthma prevalence, and wheeze in children; acceleration of lung function decline in adults; and
respiratory mortality. The epidemiologic evidence is supported by animal toxicological studies,
which provide coherence and biological plausibility for a range of effects including impaired
lung development, decrements in lung function growth, and asthma development.

Since the 2009 PM ISA, a growing body of scientific evidence examined the relationship
between long-term PM2.5 exposure and nervous system effects, resulting for the first time in a
causality determination for this health effects category of a "likely to be causal relationship." The
strongest evidence for effects on the nervous system comes from epidemiologic studies that
consistently report cognitive decrements and reductions in brain volume in adults. The effects
observed in epidemiologic studies in adults are supported by animal toxicological studies
demonstrating effects on the brain of adult animals including inflammation, morphologic
changes, and neurodegeneration of specific regions of the brain. There is more limited evidence
for neurodevelopmental effects in children with some studies reporting positive associations with
autism spectrum disorder and others providing limited evidence of an association with cognitive
function. While there is some evidence from animal toxicological studies indicating effects on
the brain (i.e., inflammatory and morphological changes) to support a biologically plausible
pathway for neurodevelopmental effects, epidemiologic studies are limited due to their lack of
control for potential confounding by co-pollutants, the small number of studies conducted, and
uncertainty regarding critical exposure windows.

Building off the decades of research demonstrating mutagenicity, DNA damage, and other
endpoints related to genotoxicity due to whole PM exposures, recent experimental and
epidemiologic studies focusing specifically on PM2.5 provide evidence of a relationship between
long-term PM2.5 exposure and cancer. Epidemiologic studies examining long-term PM2.5
exposure and lung cancer incidence and mortality provide evidence of generally positive
associations in cohort studies spanning different populations, locations, and exposure assignment
techniques. Additionally, there is evidence of positive associations with lung cancer incidence
and mortality in analyses limited to never smokers. The epidemiologic evidence is supported by
both experimental and epidemiologic evidence of genotoxicity, epigenetic effects, carcinogenic
potential, and that PM2.5 exhibits several characteristics of carcinogens, which collectively
provides biological plausibility for cancer development and resulted in the conclusion of a
"likely to be causal relationship."

For the additional health effects categories evaluated for PM2.5 in the 2019 PM ISA,
experimental and epidemiologic studies provide limited and/or inconsistent evidence of a
relationship with PM2.5 exposure. As a result, the 2019 PM ISA concluded that the evidence is
"suggestive of, but not sufficient to infer a causal relationship" for short-term PM2.5 exposure
and metabolic effects and nervous system effects and long-term PM2.5 exposures and metabolic
effects as well as reproductive and developmental effects.

In addition to evaluating the health effects attributed to short- and long-term exposure to
PM2.5, the 2019 PM ISA also conducted an extensive evaluation as to whether specific
components or sources of PM2.5 are more strongly related with specific health effects than PM2.5
mass. An evaluation of those studies resulted in the 2019 PM ISA concluding that "many PM2.5
components and sources are associated with many health effects, and the evidence does not
indicate that any one source or component is consistently more strongly related to health effects
than PM2.5 mass."33

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For both PM10-2.5 and UFPs, for all health effects categories evaluated, the 2019 PM ISA
concluded that the evidence was "suggestive of, but not sufficient to infer, a causal relationship"
or "inadequate to determine the presence or absence of a causal relationship." For PM10-2.5,
although a Federal Reference Method (FRM) was instituted in 2011 to measure PM 10-2.5
concentrations nationally, the causality determinations reflect that the same uncertainty identified
in the 2009 PM ISA with respect to the method used to estimate PM 10-2.5 concentrations in
epidemiologic studies persists. Specifically, across epidemiologic studies, different approaches
are used to estimate PM10-2.5 concentrations (e.g., direct measurement of PM10-2.5, difference
between PM10 and PM2.5 concentrations), and it remains unclear how well correlated PM10-2.5
concentrations are both spatially and temporally across the different methods used.

For UFPs, which have often been defined as particles <0.1 |im, the uncertainty in the evidence
for the health effect categories evaluated across experimental and epidemiologic studies reflects
the inconsistency in the exposure metric used (i.e., particle number concentration, surface area
concentration, mass concentration) as well as the size fractions examined. In epidemiologic
studies the size fraction examined can vary depending on the monitor used and exposure metric,
with some studies examining number count over the entire particle size range, while
experimental studies that use a particle concentrator often examine particles up to 0.3 |im.
Additionally, due to the lack of a monitoring network, there is limited information on the spatial
and temporal variability of UFPs within the U.S., as well as population exposures to UFPs,
which adds uncertainty to epidemiologic study results.

The 2019 PM ISA cites extensive evidence indicating that "both the general population as
well as specific populations and lifestages are at risk for PM2.5-related health effects,"34 For
example, in support of its "causal" and "likely to be causal" determinations, the ISA cites
substantial evidence for (1) PM-related mortality and cardiovascular effects in older adults; (2)
PM-related cardiovascular effects in people with pre-existing cardiovascular disease; (3) PM-
related respiratory effects in people with pre-existing respiratory disease, particularly asthma
exacerbations in children; and (4) PM-related impairments in lung function growth and asthma
development in children. The ISA additionally notes that stratified analyses (i.e., analyses that
directly compare PM-related health effects across groups) provide strong evidence for racial and
ethnic differences in PM2.5 exposures and in the risk of PM2.5-related health effects, specifically
within Hispanic and non-Hispanic Black populations with some evidence of increased risk for
populations of low socioeconomic status. Recent studies evaluated in the Supplement support the
conclusion of the 2019 PM ISA with respect to disparities in both PM2.5 exposure and health risk
by race and ethnicity and provide additional support for disparities for populations of lower
socioeconomic status.35 Additionally, evidence spanning epidemiologic studies that conducted
stratified analyses, experimental studies focusing on animal models of disease or individuals
with pre-existing disease, dosimetry studies, as well as studies focusing on differential exposure
suggest that populations with pre-existing cardiovascular or respiratory disease, populations that
are overweight or obese, populations that have particular genetic variants, and current/former
smokers could be at increased risk for adverse PM2.5-related health effects. The 2022 Policy
Assessment for the review of the PM NAAQS also highlights that factors that may contribute to
increased risk of PM2.5-related health effects include lifestage (children and older adults), pre-
existing diseases (cardiovascular disease and respiratory disease), race/ethnicity, and
socioeconomic status.36

5.2.3 Nitrogen Oxides

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5.2.3.1 Background on Nitrogen Oxides

Oxides of nitrogen (NOx) refers to nitric oxide (NO) and nitrogen dioxide (NO2). Most NO2
is formed in the air through the oxidation of nitric oxide (NO) that is emitted when fuel is burned
at a high temperature. NOx is a major contributor to secondary PM2.5 formation, and NOx along
with VOCs are the two major precursors of ozone.

5.2.3.2 Health Effects Associated with Exposure to Nitrogen Oxides

The most recent review of the health effects of oxides of nitrogen completed by EPA can be
found in the 2016 Integrated Science Assessment for Oxides of Nitrogen - Health Criteria
(Oxides of Nitrogen ISA).37 The primary source of NO2 is motor vehicle emissions, and ambient
NO2 concentrations tend to be highly correlated with other traffic-related pollutants. Thus, a key
issue in characterizing the causality of N02-health effect relationships consists of evaluating the
extent to which studies supported an effect of NO2 that is independent of other traffic-related
pollutants. EPA concluded that the findings for asthma exacerbation integrated from
epidemiologic and controlled human exposure studies provided evidence that is sufficient to
infer a causal relationship between respiratory effects and short-term NO2 exposure. The
strongest evidence supporting an independent effect of NO2 exposure comes from controlled
human exposure studies demonstrating increased airway responsiveness in individuals with
asthma following ambient-relevant NO2 exposures. The coherence of this evidence with
epidemiologic findings for asthma hospital admissions and ED visits as well as lung function
decrements and increased pulmonary inflammation in children with asthma describe a plausible
pathway by which NO2 exposure can cause an asthma exacerbation. The 2016 ISA for Oxides of
Nitrogen also concluded that there is likely to be a causal relationship between long-term NO2
exposure and respiratory effects. This conclusion is based on new epidemiologic evidence for
associations of NO2 with asthma development in children combined with biological plausibility
from experimental studies.

In evaluating a broader range of health effects, the 2016 ISA for Oxides of Nitrogen
concluded that evidence is "suggestive of, but not sufficient to infer, a causal relationship"
between short-term NO2 exposure and cardiovascular effects and mortality and between long-
term NO2 exposure and cardiovascular effects and diabetes, birth outcomes, and cancer. In
addition, the scientific evidence is inadequate (insufficient consistency of epidemiologic and
toxicological evidence) to infer a causal relationship for long-term NO2 exposure with fertility,
reproduction, and pregnancy, as well as with postnatal development. A key uncertainty in
understanding the relationship between these non-respiratory health effects and short- or long-
term exposure to NO2 is co-pollutant confounding, particularly by other roadway pollutants. The
available evidence for non-respiratory health effects does not adequately address whether NO2
has an independent effect or whether it primarily represents effects related to other or a mixture
of traffic-related pollutants.

The 2016 ISA for Oxides of Nitrogen concluded that people with asthma, children, and older
adults are at increased risk for N02-related health effects. In these groups and lifestages, NO2 is
consistently related to larger effects on outcomes related to asthma exacerbation, for which there
is confidence in the relationship with NO2 exposure.

5.2.4 Carbon Monoxide

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5.2.4.1 Background on Carbon Monoxide

Carbon monoxide (CO) is a colorless, odorless gas emitted from combustion processes.
Nationally, particularly in urban areas, the majority of CO emissions to ambient air come from
mobile sources.38

5.2.4.2 Health Effects Associated with Carbon Monoxide

Information on the health effects of carbon monoxide (CO) can be found in the January 2010
Integrated Science Assessment for Carbon Monoxide (CO ISA).39 The CO ISA presents
conclusions regarding the presence of causal relationships between CO exposure and categories
of adverse health effects.1X This section provides a summary of the health effects associated with
exposure to ambient concentrations of CO, along with the CO ISA conclusions.x

Controlled human exposure studies of subjects with coronary artery disease show a decrease
in the time to onset of exercise-induced angina (chest pain) and electrocardiogram changes
following CO exposure. In addition, epidemiologic studies observed associations between short-
term CO exposure and cardiovascular morbidity, particularly increased emergency room visits
and hospital admissions for coronary heart disease (including ischemic heart disease, myocardial
infarction, and angina). Some epidemiologic evidence is also available for increased hospital
admissions and emergency room visits for congestive heart failure and cardiovascular disease as
a whole. The CO ISA concludes that a causal relationship is likely to exist between short-term
exposures to CO and cardiovascular morbidity. It also concludes that available data are
inadequate to conclude that a causal relationship exists between long-term exposures to CO and
cardiovascular morbidity.

Animal studies show various neurological effects with in-utero CO exposure. Controlled
human exposure studies report central nervous system and behavioral effects following low-level
CO exposures, although the findings have not been consistent across all studies. The CO ISA
concludes that the evidence is suggestive of a causal relationship with both short- and long-term
exposure to CO and central nervous system effects.

A number of studies cited in the CO ISA have evaluated the role of CO exposure in birth
outcomes such as preterm birth or cardiac birth defects. There is limited epidemiologic evidence
of a CO-induced effect on preterm births and birth defects, with weak evidence for a decrease in
birth weight. Animal toxicological studies have found perinatal CO exposure to affect birth
weight, as well as other developmental outcomes. The CO ISA concludes that the evidence is
suggestive of a causal relationship between long-term exposures to CO and developmental
effects and birth outcomes.

Epidemiologic studies provide evidence of associations between short-term CO
concentrations and respiratory morbidity such as changes in pulmonary function, respiratory
symptoms, and hospital admissions. A limited number of epidemiologic studies considered co-

K The ISA evaluates the health evidence associated with different health effects, assigning one of five "weight of
evidence" determinations: causal relationship, likely to be a causal relationship, suggestive of a causal relationship,
inadequate to infer a causal relationship, and not likely to be a causal relationship. For definitions of these levels of
evidence, please refer to Section 1.6 of the ISA.

x Personal exposure includes contributions from many sources, and in many different environments. Total personal
exposure to CO includes both ambient and non-ambient components; and both components may contribute to
adverse health effects.

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pollutants such as ozone, SO2, and PM in two-pollutant models and found that CO risk estimates
were generally robust, although this limited evidence makes it difficult to disentangle effects
attributed to CO itself from those of the larger complex air pollution mixture. Controlled human
exposure studies have not extensively evaluated the effect of CO on respiratory morbidity.
Animal studies at levels of 50-100 ppm CO show preliminary evidence of altered pulmonary
vascular remodeling and oxidative injury. The CO ISA concludes that the evidence is suggestive
of a causal relationship between short-term CO exposure and respiratory morbidity, and
inadequate to conclude that a causal relationship exists between long-term exposure and
respiratory morbidity.

Finally, the CO ISA concludes that the epidemiologic evidence is suggestive of a causal
relationship between short-term concentrations of CO and mortality. Epidemiologic evidence
suggests an association exists between short-term exposure to CO and mortality, but limited
evidence is available to evaluate cause-specific mortality outcomes associated with CO exposure.
In addition, the attenuation of CO risk estimates which was often observed in co-pollutant
models contributes to the uncertainty as to whether CO is acting alone or as an indicator for other
combustion-related pollutants. The CO ISA also concludes that there is not likely to be a causal
relationship between relevant long-term exposures to CO and mortality.

5.2.5 Sulfur Oxides

5.2.5.1 Background on Sulfur Oxides

Sulfur dioxide (SO2), a member of the sulfur oxide (SOx) family of gases, is formed from
burning fuels containing sulfur (e.g., coal or oil), extracting gasoline from oil, or extracting
metals from ore. SO2 andits gas phase oxidation products can dissolve in water droplets and
further oxidize to form sulfuric acid which reacts with ammonia to form sulfates, which are
important components of ambient PM.

5.2.5.2 Health Effects Associated with Exposure to Sulfur Oxides

This section provides an overview of the health effects associated with SO2. Additional
information on the health effects of SO2 can be found in the 2017 Integrated Science Assessment
for Sulfur Oxides - Health Criteria (SOx ISA).40 Following an extensive evaluation of health
evidence from animal toxicological, controlled human exposure, and epidemiologic studies, the
EPA has concluded that there is a causal relationship between respiratory health effects and
short-term exposure to SO2. The immediate effect of SO2 on the respiratory system in humans is
bronchoconstriction. People with asthma are more sensitive to the effects of SO2, likely resulting
from preexisting inflammation associated with this disease. In addition to those with asthma
(both children and adults), there is suggestive evidence that all children and older adults may be
at increased risk of S02-related health effects. In free-breathing laboratory studies involving
controlled human exposures to SO2, respiratory effects have consistently been observed
following 5-10 min exposures at SO2 concentrations > 400 ppb in people with asthma engaged in
moderate to heavy levels of exercise, with respiratory effects occurring at concentrations as low
as 200 ppb in some individuals with asthma. A clear concentration-response relationship has
been demonstrated in these studies following exposures to SO2 at concentrations between 200
and 1000 ppb, both in terms of increasing severity of respiratory symptoms and decrements in
lung function, as well as the percentage of individuals with asthma adversely affected.
Epidemiologic studies have reported positive associations between short-term ambient SO2

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concentrations and hospital admissions and emergency department visits for asthma and for all
respiratory causes, particularly among children and older adults (> 65 years). The studies provide
supportive evidence for the causal relationship.

For long-term SO2 exposure and respiratory effects, the EPA has concluded that the evidence
is suggestive of a causal relationship. This conclusion is based on new epidemiologic evidence
for positive associations between long-term SO2 exposure and increases in asthma incidence
among children, together with animal toxicological evidence that provides a pathophysiologic
basis for the development of asthma. However, uncertainty remains regarding the influence of
other pollutants on the observed associations with SO2 because these epidemiologic studies have
not examined the potential for co-pollutant confounding.

Consistent associations between short-term exposure to SO2 and mortality have been observed
in epidemiologic studies, with larger effect estimates reported for respiratory mortality than for
cardiovascular mortality. While this finding is consistent with the demonstrated effects of SO2 on
respiratory morbidity, uncertainty remains with respect to the interpretation of these observed
mortality associations due to potential confounding by various co-pollutants. Therefore, the EPA
has concluded that the overall evidence is suggestive of a causal relationship between short-term
exposure to SO2 and mortality.

5.2.6 Diesel Exhaust

5.2.6.1 Background on Diesel Exhaust

Diesel exhaust is a complex mixture composed of particulate matter, carbon dioxide, oxygen,
nitrogen, water vapor, carbon monoxide, nitrogen compounds, sulfur compounds and numerous
low-molecular-weight hydrocarbons. A number of these gaseous hydrocarbon components are
individually known to be toxic, including aldehydes, benzene and 1,3-butadiene. The diesel
particulate matter present in diesel exhaust consists mostly of fine particles (< 2.5 |im), of which
a significant fraction is ultrafine particles (< 0.1 |im). These particles have a large surface area
which makes them an excellent medium for adsorbing organics, and their small size makes them
highly respirable. Many of the organic compounds present in the gases and on the particles, such
as polycyclic organic matter, are individually known to have mutagenic and carcinogenic
properties.

Diesel exhaust varies significantly in chemical composition and particle sizes between
different engine types (heavy-duty, light-duty), engine operating conditions (idle, acceleration,
deceleration), and fuel formulations (high/low sulfur fuel). Also, there are emissions differences
between on-road and nonroad engines because the nonroad engines are generally of older
technology. After being emitted in the engine exhaust, diesel exhaust undergoes dilution as well
as chemical and physical changes in the atmosphere. The lifetime of the components present in
diesel exhaust ranges from seconds to days.

5.2.6.2 Health Effects Associated with Exposure to Diesel Exhaust

In EPA's 2002 Diesel Health Assessment Document (Diesel HAD), exposure to diesel
exhaust was classified as likely to be carcinogenic to humans by inhalation from environmental
exposures, in accordance with the revised draft 1996/1999 EPA cancer guidelines.41'42 A number
of other agencies (National Institute for Occupational Safety and Health, the International
Agency for Research on Cancer, the World Health Organization, California EPA, and the U.S.

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Department of Health and Human Services) made similar hazard classifications prior to 2002.
EPA also concluded in the 2002 Diesel HAD that it was not possible to calculate a cancer unit
risk for diesel exhaust due to limitations in the exposure data for the occupational groups or the
absence of a dose-response relationship.

In the absence of a cancer unit risk, the Diesel HAD sought to provide additional insight into
the significance of the diesel exhaust cancer hazard by estimating possible ranges of risk that
might be present in the population. An exploratory analysis was used to characterize a range of
possible lung cancer risk. The outcome was that environmental risks of cancer from long-term
diesel exhaust exposures could plausibly range from as low as 10"5 to as high as 10"3. Because of
uncertainties, the analysis acknowledged that the risks could be lower than 10"5, and a zero risk
from diesel exhaust exposure could not be ruled out.

Noncancer health effects of acute and chronic exposure to diesel exhaust emissions are also of
concern to EPA. EPA derived a diesel exhaust reference concentration (RfC) from consideration
of four well-conducted chronic rat inhalation studies showing adverse pulmonary effects. The
RfC is 5 |ig/m3 for diesel exhaust measured as diesel particulate matter. This RfC does not
consider allergenic effects such as those associated with asthma or immunologic or the potential
for cardiac effects. There was emerging evidence in 2002, discussed in the Diesel HAD, that
exposure to diesel exhaust can exacerbate these effects, but the exposure-response data were
lacking at that time to derive an RfC based on these then-emerging considerations. The Diesel
HAD states, "With [diesel particulate matter] being a ubiquitous component of ambient PM,
there is an uncertainty about the adequacy of the existing [diesel exhaust] noncancer database to
identify all of the pertinent [diesel exhaust]-caused noncancer health hazards." The Diesel HAD
also notes "that acute exposure to [diesel exhaust] has been associated with irritation of the eye,
nose, and throat, respiratory symptoms (cough and phlegm), and neurophysiological symptoms
such as headache, lightheadedness, nausea, vomiting, and numbness or tingling of the
extremities." The Diesel HAD notes that the cancer and noncancer hazard conclusions applied to
the general use of diesel engines then on the market and as cleaner engines replace a substantial
number of existing ones, the applicability of the conclusions would need to be reevaluated.

It is important to note that the Diesel HAD also briefly summarizes health effects associated
with ambient PM and discusses EPA's then-annual PM2.5 NAAQS of 15 |ig/m3xi. There is a
large and extensive body of human data showing a wide spectrum of adverse health effects
associated with exposure to ambient PM, of which diesel exhaust is an important component.
The PM2.5 NAAQS is designed to provide protection from the noncancer health effects and
premature mortality attributed to exposure to PM2.5. The contribution of diesel PM to total
ambient PM varies in different regions of the country and also, within a region, from one area to
another. The contribution can be high in near-roadway environments, for example, or in other
locations where diesel engine use is concentrated.

Since 2002, several new studies have been published which continue to report increased lung
cancer risk associated with occupational exposure to diesel exhaust from older engines. Of
particular note since 2011 are three new epidemiology studies which have examined lung cancer
in occupational populations, including truck drivers, underground nonmetal miners and other
diesel motor-related occupations. These studies reported increased risk of lung cancer related to

X1 See Chapter 5.2.2.1 for discussion of the current PM2.5 NAAQS standard, and https://www.epa.gov/pm-
pollution/national-ambient-air-quality-standards-naaqs-pm.

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exposure to diesel exhaust, with evidence of positive exposure-response relationships to varying
degrees.43'44'45 These newer studies (along with others that have appeared in the scientific
literature) add to the evidence EPA evaluated in the 2002 Diesel HAD and further reinforce the
concern that diesel exhaust exposure likely poses a lung cancer hazard. The findings from these
newer studies do not necessarily apply to newer technology diesel engines (i.e., heavy-duty
highway engines from 2007 and later model years) since the newer engines have large reductions
in the emission constituents compared to older technology diesel engines.

In light of the growing body of scientific literature evaluating the health effects of exposure to
diesel exhaust, in June 2012 the World Health Organization's International Agency for Research
on Cancer (IARC), a recognized international authority on the carcinogenic potential of
chemicals and other agents, evaluated the full range of cancer-related health effects data for
diesel engine exhaust. IARC concluded that diesel exhaust should be regarded as "carcinogenic
to humans."46 This designation was an update from its 1988 evaluation that considered the
evidence to be indicative of a "probable human carcinogen."

5.2.7 Air Toxics

Heavy-duty engine emissions contribute to ambient levels of air toxics that are known or
suspected human or animal carcinogens or that have noncancer health effects. These compounds
include, but are not limited to, acetaldehyde, acrolein, benzene, 1,3-butadiene, ethylbenzene,
formaldehyde, and naphthalene. These compounds were identified as national or regional cancer
risk drivers or contributors in the 2018 AirToxScreen Assessment.47'48

5.2.7.1 Acetaldehyde

Acetaldehyde is classified in EPA's IRIS database as a probable human carcinogen, based on
nasal tumors in rats, and is considered toxic by the inhalation, oral, and intravenous routes.49 The
inhalation unit risk assessment (URE) in IRIS for acetaldehyde is 2.2 x 10"6 per |ig/m3.50
Acetaldehyde is reasonably anticipated to be a human carcinogen by the NTP in the 14th Report
on Carcinogens and is classified as possibly carcinogenic to humans (Group 2B) by the
IARC.51'52

The primary noncancer effects of exposure to acetaldehyde vapors include irritation of the
eyes, skin, and respiratory tract.53 In short-term (4 week) rat studies, degeneration of olfactory
epithelium was observed at various concentration levels of acetaldehyde exposure.54'55 Data from
these studies were used by EPA to develop an inhalation reference concentration of 9 |ig/m3.
Some asthmatics have been shown to be a sensitive subpopulation to decrements in functional
expiratory volume (FEV1 test) and bronchoconstriction upon acetaldehyde inhalation.56
Children, especially those with diagnosed asthma, may be more likely to show impaired
pulmonary function and symptoms of asthma than are adults following exposure to
acetaldehyde.57

5.2.7.1 Acrolein

EPA most recently evaluated the toxicological and health effects literature related to acrolein
in 2003 and concluded that the human carcinogenic potential of acrolein could not be determined
because the available data were inadequate. No information was available on the carcinogenic
effects of acrolein in humans, and the animal data provided inadequate evidence of
carcinogenicity.58 In 2021, the IARC classified acrolein as probably carcinogenic to humans.59

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Lesions to the lungs and upper respiratory tract of rats, rabbits, and hamsters have been
observed after subchronic exposure to acrolein.60 The agency has developed an RfC for acrolein
of 0.02 |ig/m3 and an RfD of 0.5 |ig/kg-day.61

Acrolein is extremely acrid and irritating to humans when inhaled, with acute exposure
resulting in upper respiratory tract irritation, mucus hypersecretion and congestion. The intense
irritancy of this carbonyl has been demonstrated during controlled tests in human subjects, who
suffer intolerable eye and nasal mucosal sensory reactions within minutes of exposure.62 These
data and additional studies regarding acute effects of human exposure to acrolein are
summarized in EPA's 2003 IRIS Human Health Assessment for acrolein.63 Studies in humans
indicate that levels as low as 0.09 ppm (0.21 mg/m3) for five minutes may elicit subjective
complaints of eye irritation with increasing concentrations leading to more extensive eye, nose
and respiratory symptoms. Acute exposures in animal studies report bronchial hyper-
responsiveness. Based on animal data (more pronounced respiratory irritancy in mice with
allergic airway disease in comparison to non-diseased mice64) and demonstration of similar
effects in humans (e.g., reduction in respiratory rate), individuals with compromised respiratory
function (e.g., emphysema, asthma) are expected to be at increased risk of developing adverse
responses to strong respiratory irritants such as acrolein. EPA does not currently have an acute
reference concentration for acrolein. The available health effect reference values for acrolein
have been summarized by EPA and include an ATSDR MRL for acute exposure to acrolein of 7
|ig/m3 for 1-14 days exposure and Reference Exposure Level (REL) values from the California
Office of Environmental Health Hazard Assessment (OEHHA) for one-hour and 8-hour
exposures of 2.5 |ig/m3 and 0.7 |ig/m3, respectively.65

5.2.7.2 Benzene

EPA's Integrated Risk Information System (IRIS) database lists benzene as a known human
carcinogen (causing leukemia) by all routes of exposure and concludes that exposure is
associated with additional health effects, including genetic changes in both humans and animals
and increased proliferation of bone marrow cells in mice.66'67'68 EPA states in its IRIS database
that data indicate a causal relationship between benzene exposure and acute lymphocytic
leukemia and suggest a relationship between benzene exposure and chronic non-lymphocytic
leukemia and chronic lymphocytic leukemia. EPA's IRIS documentation for benzene also lists a
range of 2.2 x 10"6 to 7.8 x 10"6 per |ig/m3 as the unit risk estimate (URE) for benzene.X11'69 The
IARC has determined that benzene is a human carcinogen, and the U.S. Department of Health
and Human Services (DHHS) has characterized benzene as a known human carcinogen.70'71

A number of adverse noncancer health effects, including blood disorders such as preleukemia
and aplastic anemia, have also been associated with long-term exposure to benzene.72'73 The
most sensitive noncancer effect observed in humans, based on current data, is the depression of
the absolute lymphocyte count in blood.74'75 EPA's inhalation reference concentration (RfC) for
benzene is 30 |ig/m3. The RfC is based on suppressed absolute lymphocyte counts seen in
humans under occupational exposure conditions. In addition, studies sponsored by the Health
Effects Institute (HEI) provide evidence that biochemical responses occur at lower levels of
benzene exposure than previously known.76'77'78'79 EPA's IRIS program has not yet evaluated
these new data. EPA does not currently have an acute reference concentration for benzene. The

xn A unit risk estimate is defined as the increase in the lifetime risk of an individual who is exposed for a lifetime to
1 Hg/m3 benzene in air.

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Agency for Toxic Substances and Disease Registry (ATSDR) Minimal Risk Level (MRL) for
acute inhalation exposure to benzene is 29 |ig/m3 for 1-14 days exposure.80'™1

There is limited information from two studies regarding an increased risk of adverse effects to
children whose parents have been occupationally exposed to benzene.81'82Data from animal
studies have shown benzene exposures result in damage to the hematopoietic (blood cell
formation) system during development.83'84'85 Also, key changes related to the development of
childhood leukemia occur in the developing fetus.86 Several studies have reported that genetic
changes related to eventual leukemia development occur before birth. For example, there is one
study of genetic changes in twins who developed T cell leukemia at nine years of age.87

5.2.7.1 1,3-Butadiene

EPA has characterized 1,3-butadiene as carcinogenic to humans by inhalation.88'89 The IARC
has determined that 1,3-butadiene is a human carcinogen, and the U.S. DHHS has characterized
1,3-butadiene as a known human carcinogen.90'91'92'93 There are numerous studies consistently
demonstrating that 1,3-butadiene is metabolized into genotoxic metabolites by experimental
animals and humans. The specific mechanisms of 1,3-butadiene-induced carcinogenesis are
unknown; however, the scientific evidence strongly suggests that the carcinogenic effects are
mediated by genotoxic metabolites. Animal data suggest that females may be more sensitive than
males for cancer effects associated with 1,3-butadiene exposure; there are insufficient data in
humans from which to draw conclusions about sensitive subpopulations. The URE for 1,3-
butadiene is 3 x 10"5 per |ig/m3,94 1,3-butadiene also causes a variety of reproductive and
developmental effects in mice; no human data on these effects are available. The most sensitive
effect was ovarian atrophy observed in a lifetime bioassay of female mice.95 Based on this
critical effect and the benchmark concentration methodology, an RfC for chronic health effects
was calculated at 0.9 ppb (approximately 2 |ig/m3).

5.2.7.2 Ethylbenzene

EPA's inhalation RfC for ethylbenzene is 1 mg/m3. This conclusion on a weight of evidence
determination and RfC is contained in the 1991 IRIS file for ethylbenzene.96 The RfC is based on
developmental effects. A study in rabbits found reductions in live rabbit kits per litter at 1000
ppm. In addition, a study on rats found an increased incidence of supernumerary and rudimentary
ribs at 1000 ppm and elevated incidence of extra ribs at 100 ppm. In 1988, EPA concluded that
data were inadequate to give a weight of evidence characterization for carcinogenic effects. EPA
released an IRIS Assessment Plan for Ethylbenzene in 2017,97 and EPA will be releasing the
Systematic Review Protocol for ethylbenzene in 2023.98

California EPA completed a cancer risk assessment for ethylbenzene in 2007 and developed
an inhalation unit risk estimate of 2.5xl0"6.99 This value was based on incidence of kidney cancer
in male rats. California EPA also developed a chronic inhalation noncancer reference exposure
level (REL) of 2000 |ig/m3, based on nephrotoxicity and body weight reduction in rats, liver
cellular alterations, necrosis in mice, and hyperplasia of the pituitary gland in mice.100

xm A minimal risk level (MRL) is defined as an estimate of the daily human exposure to a hazardous substance that
is likely to be without appreciable risk of adverse noncancer health effects over a specified duration of exposure.

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ATSDR developed a chronic inhalation Minimal Risk Level (MRL) for ethylbenzene of 0.06
ppm based on renal effects and an acute MRL of 5 ppm based on auditory effects.

5.2.7.3 Formaldehyde

In 1991, EPA concluded that formaldehyde is a Class B1 probable human carcinogen based
on limited evidence in humans and sufficient evidence in animals.101 An inhalation URE for
cancer and a reference dose for oral noncancer effects were developed by EPA and posted on the
IRIS database. Since that time, the NTP and IARC have concluded that formaldehyde is a known
human carcinogen.102'103'104

The conclusions by IARC and NTP reflect the results of epidemiologic research published
since 1991 in combination with previous animal, human and mechanistic evidence. Research
conducted by the National Cancer Institute reported an increased risk of nasopharyngeal cancer
and specific lymphohematopoietic malignancies among workers exposed to
formaldehyde.105'106'107 A National Institute of Occupational Safety and Health study of garment
workers also reported increased risk of death due to leukemia among workers exposed to
formaldehyde.108 Extended follow-up of a cohort of British chemical workers did not report
evidence of an increase in nasopharyngeal or lymphohematopoietic cancers, but a continuing
statistically significant excess in lung cancers was reported.109 Finally, a study of embalmers
reported formaldehyde exposures to be associated with an increased risk of myeloid leukemia
but not brain cancer.110

Health effects of formaldehyde in addition to cancer were reviewed by the Agency for Toxics
Substances and Disease Registry in 1999, supplemented in 2010, and by the World Health
Organization. 11l2J 13 These organizations reviewed the scientific literature concerning health
effects linked to formaldehyde exposure to evaluate hazards and dose response relationships and
defined exposure concentrations for minimal risk levels (MRLs). The health endpoints reviewed
included sensory irritation of eyes and respiratory tract, reduced pulmonary function, nasal
histopathology, and immune system effects. In addition, research on reproductive and
developmental effects and neurological effects was discussed along with several studies that
suggest that formaldehyde may increase the risk of asthma - particularly in the young.

In June 2010, EPA released a draft Toxicological Review of Formaldehyde - Inhalation
Assessment through the IRIS program for peer review by the National Research Council (NRC)
and public comment.114 That draft assessment reviewed more recent research from animal and
human studies on cancer and other health effects. The NRC released their review report in April

2011.115 EPA's draft assessment, which addresses NRC recommendations, was suspended in

2018.116 The draft assessment was unsuspended in March 2021, and an external review draft was
released in April 2022.117 This draft assessment is now undergoing review by the National
Academy of Sciences.118

5.2.7.4 Naphthalene

Naphthalene is found in small quantities in gasoline and diesel fuels. Naphthalene emissions
have been measured in larger quantities in both gasoline and diesel exhaust compared with
evaporative emissions from mobile sources, indicating it is primarily a product of combustion.

Acute (short-term) exposure of humans to naphthalene by inhalation, ingestion, or dermal
contact is associated with hemolytic anemia and damage to the liver and the nervous system.119

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Chronic (long term) exposure of workers and rodents to naphthalene has been reported to cause
cataracts and retinal damage.120 Children, especially neonates, appear to be more susceptible to
acute naphthalene poisoning based on the number of reports of lethal cases in children and
infants (hypothesized to be due to immature naphthalene detoxification pathways).121 EPA
released an external review draft of a reassessment of the inhalation carcinogenicity of
naphthalene based on a number of recent animal carcinogenicity studies.122 The draft
reassessment completed external peer review.123 Based on external peer review comments
received, EPA is developing a revised draft assessment that considers inhalation and oral routes
of exposure, as well as cancer and noncancer effects.124 The external review draft does not
represent official agency opinion and was released solely for the purposes of external peer
review and public comment. The NTP listed naphthalene as "reasonably anticipated to be a
human carcinogen" in 2004 on the basis of bioassays reporting clear evidence of carcinogenicity
in rats and some evidence of carcinogenicity in mice.125 California EPA has released a new risk
assessment for naphthalene, and the IARC has reevaluated naphthalene and re-classified it as
Group 2B: possibly carcinogenic to humans.126

Naphthalene also causes a number of non-cancer effects in animals following chronic and
less-than-chronic exposure, including abnormal cell changes and growth in respiratory and nasal
tissues.127 The current EPA IRIS assessment includes noncancer data on hyperplasia and
metaplasia in nasal tissue that form the basis of the inhalation RfC of 3 |ig/m3.128 The ATSDR
MRL for acute and intermediate duration oral exposure to naphthalene is 0.6 mg/kg/day based
on maternal toxicity in a developmental toxicology study in rats.129 ATSDR also derived an ad
hoc reference value of 6 x 10"2 mg/m3 for acute (<24-hour) inhalation exposure to naphthalene in
a Letter Health Consultation dated March 24, 2014 to address a potential exposure concern in
Illinois.130 The ATSDR acute inhalation reference value was based on a qualitative identification
of an exposure level interpreted not to cause pulmonary lesions in mice. More recently, EPA
developed acute RfCs for 1-, 8-, and 24-hour exposure scenarios; the <24-hour reference value is
2 x 10"2 mg/m3.131 EPA's acute RfCs are based on a systematic review of the literature,
benchmark dose modeling of naphthalene-induced nasal lesions in rats, and application of a
PBPK (physiologically based pharmacokinetic) model.

5.2.8 Exposure and Health Effects Associated with Traffic

Locations in close proximity to major roadways generally have elevated concentrations of
many air pollutants emitted from motor vehicles. Hundreds of studies have been published in
peer-reviewed journals, concluding that concentrations of CO, CO2, NO, NO2, benzene,
aldehydes, particulate matter, black carbon, and many other compounds are elevated in ambient
air within approximately 300-600 meters (about 1,000-2,000 feet) of major roadways. The
highest concentrations of most pollutants emitted directly by motor vehicles are found at
locations within 50 meters (about 165 feet) of the edge of a roadway's traffic lanes.

A large-scale review of air quality measurements in the vicinity of major roadways between
1978 and 2008 concluded that the pollutants with the steepest concentration gradients in
vicinities of roadways were CO, ultrafine particles, metals, elemental carbon (EC), NO, NOx,
and several VOCs.132 These pollutants showed a large reduction in concentrations within 100
meters downwind of the roadway. Pollutants that showed more gradual reductions with distance
from roadways included benzene, NO2, PM2.5, and PM10. In reviewing the literature, Karner et al.
(2010) reported that results varied based on the method of statistical analysis used to determine

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the gradient in pollutant concentration. More recent studies continue to show significant
concentration gradients of traffic-related air pollution around major roads 133>134>135>136>137; 138,139,140
There is evidence that EPA's regulations for vehicles have lowered the near-road concentrations
and gradients.141 Starting in 2010, EPA required through the NAAQS process that air quality
monitors be placed near high-traffic roadways for determining concentrations of CO, NO2, and
PM2.5 (in addition to those existing monitors located in neighborhoods and other locations farther
away from pollution sources). The monitoring data for NO2 indicate that in urban areas, monitors
near roadways often report the highest concentrations of NO2.142 More recent studies of traffic-
related air pollutants continue to report sharp gradients around roadways, particularly within
several hundred meters.143'144

For pollutants with relatively high background concentrations relative to near-road
concentrations, detecting concentration gradients can be difficult. For example, many carbonyls
have high background concentrations as a result of photochemical breakdown of precursors from
many different organic compounds. However, several studies have measured carbonyls in
multiple weather conditions and found higher concentrations of many carbonyls downwind of
roadways.145'146 These findings suggest a substantial roadway source of these carbonyls.

In the past 30 years, many studies have been published with results reporting that populations
who live, work, or go to school near high-traffic roadways experience higher rates of numerous
adverse health effects, compared to populations far away from major roads.147 In addition,
numerous studies have found adverse health effects associated with spending time in traffic, such
as commuting or walking along high-traffic roadways, including studies among
children.148'149'150'151 The health outcomes with the strongest evidence linking them with traffic-
associated air pollutants are respiratory effects, particularly in asthmatic children, and
cardiovascular effects.

Numerous reviews of this body of health literature have been published. In a 2022 final
report, an expert panel of the Health Effects Institute (HEI) employed a systematic review
focusing on selected health endpoints related to exposure to traffic-related air pollution.152 The
HEI panel concluded that there was a high level of confidence in evidence between long-term
exposure to traffic-related air pollution and health effects in adults, including all-cause,
circulatory, and ischemic heart disease mortality.153 The panel also found that there is a
moderate-to-high level of confidence in evidence of associations with asthma onset and acute
respiratory infections in children and lung cancer and asthma onset in adults. This report follows
on an earlier expert review published by HEI in 2010, where it found strongest evidence for
asthma-related traffic impacts. Other literature reviews have been published with conclusions
generally similar to the HEI panels'.154'155'156'157 Additionally, in 2014, researchers from the U.S.
Centers for Disease Control and Prevention (CDC) published a systematic review and meta-
analysis of studies evaluating the risk of childhood leukemia associated with traffic exposure and
reported positive associations between "postnatal" proximity to traffic and leukemia risks, but no
such association for "prenatal" exposures.158 The U.S. Department of Health and Human
Services' National Toxicology Program published a monograph including a systematic review of
traffic-related air pollution and its impacts on hypertensive disorders of pregnancy. The National
Toxicology Program concluded that exposure to traffic-related air pollution is "presumed to be a
hazard to pregnant women" for developing hypertensive disorders of pregnancy.159

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Health outcomes with few publications suggest the possibility of other effects still lacking
sufficient evidence to draw definitive conclusions. Among these outcomes with a small number
of positive studies are neurological impacts (e.g., autism and reduced cognitive function) and
reproductive outcomes (e.g., preterm birth, low birth weight).160'161'162'163'164

In addition to health outcomes, particularly cardiopulmonary effects, conclusions of numerous
studies suggest mechanisms by which traffic-related air pollution affects health. For example,
numerous studies indicate that near-roadway exposures may increase systemic inflammation,
affecting organ systems, including blood vessels and lungs 165>166>167>168 Additionally, long-term
exposures in near-road environments have been associated with inflammation-associated
conditions, such as atherosclerosis and asthma.169'170'171

Several studies suggest that some factors may increase susceptibility to the effects of traffic-
associated air pollution. Several studies have found stronger respiratory associations in children
experiencing chronic social stress, such as in violent neighborhoods or in homes with high
family stress.172'173'174

The risks associated with residence, workplace, or schools near major roads are of potentially
high public health significance due to the large population in such locations. Every two years
from 1997 to 2009 and in 2011, the U.S. Census Bureau's American Housing Survey (AHS)
conducted a survey that includes whether housing units are within 300 feet of an "airport,
railroad, or highway with four or more lanes."X1V The 2013 AHS was the last AHS that included
that question. The 2013 survey reports that 17.3 million housing units, or 13 percent of all
housing units in the U.S., were in such areas. Assuming that populations and housing units are in
the same locations, this corresponds to a population of more than 41 million U.S. residents in
close proximity to high-traffic roadways or other transportation sources. According to the
Central Intelligence Agency's World Factbook, based on data collected between 2012-2021 the
United States had 6,586,610 km of roadways, 293,564 km of railways, and 13,513 airports.xv As
such, highways represent the overwhelming majority of transportation facilities described by this
factor in the AHS.

EPA also conducted a study to estimate the number of people living near truck freight routes
in the United States.175 Based on a population analysis using the U.S. Department of
Transportation's (USDOT) Freight Analysis Framework 4 (FAF4) and population data from the
2010 decennial census, an estimated 72 million people live within 200 meters (about 650 feet) of
these freight routes.XV1,XV" In addition, as described in Section VI.D.2, relative to the rest of the
population, people of color and those with lower incomes are more likely to live near FAF4 truck

Xlv The variable was known as "ETRANS" in the questions about the neighborhood.

xv According to the Bureau of Transportation Statistics' Transportation Statistics Annual Report for 2020, the most
recent year for which data are published, there were 6,713,652 km of roadways, 147,663 km of railways, and 20,231
airports. However, it appears that BTS and the CIA use different methods for counting, so the two estimates are not
comparable.

XV1FAF4 is a model from the USDOT's Bureau of Transportation Statistics (BTS) and Federal Highway
Administration (FHWA), which provides data associated with freight movement in the U.S. It includes data from
the 2012 Commodity Flow Survey (CFS), the Census Bureau on international trade, as well as data associated with
construction, agriculture, utilities, warehouses, and other industries. FAF4 estimates the modal choices for moving
goods by trucks, trains, boats, and other types of freight modes. It includes traffic assignments, including truck
flows on a network of truck routes, https://ops.fhwa.dot.gov/freight/freight_analysis/faf/.
xvu The same analysis estimated the population living within 100 meters of a FAF4 truck route is 41 million.

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routes. They are also more likely to live in metropolitan areas. The EPA's Exposure Factor
Handbook also indicates that, on average, Americans spend more than an hour traveling each
day, bringing nearly all residents into a high-exposure microenvironment for part of the day.176
While near-roadway studies focus on residents near roads or others spending considerable time
near major roads, the duration of commuting results in another important contributor to overall
exposure to traffic-related air pollution. Studies of health that address time spent in transit have
found evidence of elevated risk of cardiac impacts.177'178'179 Studies have also found that school
bus emissions can increase student exposures to diesel-related air pollutants, and that programs
that reduce school bus emissions may improve health and reduce school absenteeism.180'181'182'183

As described in Section 5.4.2, we estimate that about 10 million students attend schools within
200 meters of major roads. Research into the impact of traffic-related air pollution on school
performance is tentative. A review of this literature found some evidence that children exposed
to higher levels of traffic-related air pollution show poorer academic performance than those
exposed to lower levels of traffic-related air pollution.184'185 However, this evidence was judged
to be weak due to limitations in the assessment methods.

5.3 Welfare Effects Associated with Exposure to Non-GHG Pollutants

This section discusses the environmental effects associated with criteria and toxic pollutants
affected by this proposed rule.

5.3.1 Visibility

Visibility can be defined as the degree to which the atmosphere is transparent to visible
light.186 Visibility impairment is caused by light scattering and absorption by suspended
particles and gases. It is dominated by contributions from suspended particles except under
pristine conditions. Visibility is important because it has direct significance to people's
enjoyment of daily activities in all parts of the country. Individuals value good visibility for the
well-being it provides them directly, where they live and work and in places where they enjoy
recreational opportunities. Visibility is also highly valued in significant natural areas, such as
national parks and wilderness areas, and special emphasis is given to protecting visibility in these
areas. For more information on visibility see the final 2019 PM ISA.187

EPA is working to address visibility impairment. Reductions in air pollution from
implementation of various programs associated with the Clean Air Act Amendments of 1990
provisions have resulted in substantial improvements in visibility and will continue to do so in
the future. Nationally, because trends in haze are closely associated with trends in particulate
sulfate and nitrate due to the relationship between their concentration and light extinction,
visibility trends have improved as emissions of SO2 and NOx have decreased over time due to air
pollution regulations such as the Acid Rain Program.188 However, in the western part of the
country, changes in total light extinction were smaller, and the contribution of particulate organic
matter to atmospheric light extinction was increasing due to increasing wildfire emissions.189

In the Clean Air Act Amendments of 1977, Congress recognized visibility's value to society
by establishing a national goal to protect national parks and wilderness areas from visibility
impairment caused by manmade pollution.190 In 1999, EPA finalized the regional haze program
to protect the visibility in Mandatory Class I Federal areas.191 There are 156 national parks,
forests and wilderness areas categorized as Mandatory Class I Federal areas.192 These areas are

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defined in CAA section 162 as those national parks exceeding 6,000 acres, wilderness areas and
memorial parks exceeding 5,000 acres, and all international parks which were in existence on
August 7, 1977.

EPA has also concluded that PM2.5 causes adverse effects on visibility in other areas that are
not targeted by the Regional Haze Rule, such as urban areas, depending on PM2.5 concentrations
and other factors such as dry chemical composition and relative humidity (i.e., an indicator of the
water composition of the particles). The secondary (welfare-based) PM NAAQS provide
protection against visibility effects. In recent PM NAAQS reviews, EPA evaluated a target level
of protection for visibility impairment that is expected to be met through attainment of the
existing secondary PM standards.193

5.3.2 Ozone Effects on Ecosystems

The welfare effects of ozone include effects on ecosystems, which can be observed across a
variety of scales, i.e., subcellular, cellular, leaf, whole plant, population and ecosystem. Ozone
effects that begin at small spatial scales, such as the leaf of an individual plant, when they occur
at sufficient magnitudes (or to a sufficient degree), can result in effects being propagated along a
continuum to higher and higher levels of biological organization. For example, effects at the
individual plant level, such as altered rates of leaf gas exchange, growth and reproduction, can,
when widespread, result in broad changes in ecosystems, such as productivity, carbon storage,
water cycling, nutrient cycling, and community composition.

Ozone can produce both acute and chronic injury in sensitive plant species depending on the
concentration level and the duration of the exposure.194 In those sensitive speciesxvm, effects from
repeated exposure to ozone throughout the growing season of the plant can tend to accumulate,
so that even relatively low concentrations experienced for a longer duration have the potential to
create chronic stress on vegetation. 195>X1X Ozone damage to sensitive plant species includes
impaired photosynthesis and visible injury to leaves. The impairment of photosynthesis, the
process by which the plant makes carbohydrates (its source of energy and food), can lead to
reduced crop yields, timber production, and plant productivity and growth. Impaired
photosynthesis can also lead to a reduction in root growth and carbohydrate storage below
ground, resulting in other, more subtle plant and ecosystems impacts.196 These latter impacts
include increased susceptibility of plants to insect attack, disease, harsh weather, interspecies
competition and overall decreased plant vigor. The adverse effects of ozone on areas with
sensitive species could potentially lead to species shifts and loss from the affected ecosystems,xx
resulting in a loss or reduction in associated ecosystem goods and services.197 Additionally,
visible ozone injury to leaves can result in a loss of aesthetic value in areas of special scenic
significance like national parks and wilderness areas and reduced use of sensitive ornamentals in
landscaping.198 In addition to ozone effects on vegetation, newer evidence suggests that ozone

xvm Only a small percentage of all the plant species growing within the U.S. (over 43,000 species have been
catalogued in the USDA PLANTS database) have been studied with respect to ozone sensitivity.

X1X The concentration at which ozone levels overwhelm a plant's ability to detoxify or compensate for oxidant
exposure varies. Thus, whether a plant is classified as sensitive or tolerant depends in part on the exposure levels
being considered.

** Per footnote above, ozone impacts could be occurring in areas where plant species sensitive to ozone have not yet
been studied or identified.

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affects interactions between plants and insects by altering chemical signals (e.g., floral scents)
that plants use to communicate to other community members, such as attraction of pollinators.

The Ozone ISA presents more detailed information on how ozone affects vegetation and
ecosystems.199 The Ozone ISA reports causal and likely causal relationships between ozone
exposure and a number of welfare effects and characterizes the weight of evidence for different
effects associated with ozone.XX1 The Ozone ISA concludes that visible foliar injury effects on
vegetation, reduced vegetation growth, reduced plant reproduction, reduced productivity in
terrestrial ecosystems, reduced yield and quality of agricultural crops, alteration of below-ground
biogeochemical cycles, and altered terrestrial community composition are causally associated
with exposure to ozone. It also concludes that increased tree mortality, altered herbivore growth
and reproduction, altered plant-insect signaling, reduced carbon sequestration in terrestrial
ecosystems, and alteration of terrestrial ecosystem water cycling are likely to be causally
associated with exposure to ozone.

5.3.3 Deposition

The Integrated Science Assessment for Oxides of Nitrogen, Oxides of Sulfur, and Particulate
Matter - Ecological Criteria documents the ecological effects of the deposition of these criteria
air pollutants.200 It is clear from the body of evidence that oxides of nitrogen, oxides of sulfur,
and particulate matter contribute to total nitrogen (N) and sulfur (S) deposition. In turn, N and S
deposition cause either nutrient enrichment or acidification depending on the sensitivity of the
landscape or the species in question. Both enrichment and acidification are characterized by an
alteration of the biogeochemistry and the physiology of organisms, resulting in harmful declines
in biodiversity in terrestrial, freshwater, wetland, and estuarine ecosystems in the U.S. Decreases
in biodiversity mean that some species become relatively less abundant and may be locally
extirpated. In addition to the loss of unique living species, the decline in total biodiversity can be
harmful because biodiversity is an important determinant of the stability of ecosystems and their
ability to provide socially valuable ecosystem services.

Terrestrial, wetland, freshwater, and estuarine ecosystems in the U.S. are affected by N
enrichment/eutrophication caused by N deposition. These effects have been consistently
documented across the U.S. for hundreds of species. In aquatic systems increased nitrogen can
alter species assemblages and cause eutrophication. In terrestrial systems nitrogen loading can
lead to loss of nitrogen-sensitive lichen species, decreased biodiversity of grasslands, meadows
and other sensitive habitats, and increased potential for invasive species.

The sensitivity of terrestrial and aquatic ecosystems to acidification from nitrogen and sulfur
deposition is predominantly governed by geology. Prolonged exposure to excess nitrogen and
sulfur deposition in sensitive areas acidifies lakes, rivers, and soils. Increased acidity in surface
waters creates inhospitable conditions for biota and affects the abundance and biodiversity of
fishes, zooplankton and macroinvertebrates and ecosystem function. Over time, acidifying
deposition also removes essential nutrients from forest soils, depleting the capacity of soils to
neutralize future acid loadings and negatively affecting forest sustainability. Major effects in

XX1 The Ozone ISA evaluates the evidence associated with different ozone related health and welfare effects,
assigning one of five "weight of evidence" determinations: causal relationship, likely to be a causal relationship,
suggestive of a causal relationship, inadequate to infer a causal relationship, and not likely to be a causal
relationship. For more information on these levels of evidence, please refer to Table II of the ISA.

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forests include a decline in sensitive tree species, such as red spruce (Picea rubens) and sugar
maple (Acer saccharum).

Building materials including metals, stones, cements, and paints undergo natural weathering
processes from exposure to environmental elements (e.g., wind, moisture, temperature
fluctuations, sunlight, etc.). Pollution can worsen and accelerate these effects. Deposition of PM
is associated with both physical damage (materials damage effects) and impaired aesthetic
qualities (soiling effects). Wet and dry deposition of PM can physically affect materials, adding
to the effects of natural weathering processes, by potentially promoting or accelerating the
corrosion of metals, by degrading paints and by deteriorating building materials such as stone,
concrete and marble.201 The effects of PM are exacerbated by the presence of acidic gases and
can be additive or synergistic due to the complex mixture of pollutants in the air and surface
characteristics of the material. Acidic deposition has been shown to have an effect on materials
including zinc/galvanized steel and other metal, carbonate stone (as monuments and building
facings), and surface coatings (paints).202 The effects on historic buildings and outdoor works of
art are of particular concern because of the uniqueness and irreplaceability of many of these
objects. In addition to aesthetic and functional effects on metals, stone and glass, altered energy
efficiency of photovoltaic panels by PM deposition is also becoming an important consideration
for impacts of air pollutants on materials.

5.3.4 Welfare Effects of Air Toxics

Emissions from producing, transporting, and combusting fuel contribute to ambient levels of
pollutants that contribute to adverse effects on vegetation. Volatile organic compounds (VOCs),
some of which are considered air toxics, have long been suspected to play a role in vegetation
damage.203 In laboratory experiments, a wide range of tolerance to VOCs has been observed.204
Decreases in harvested seed pod weight have been reported for the more sensitive plants, and
some studies have reported effects on seed germination, flowering, and fruit ripening. Effects of
individual VOCs or their role in conjunction with other stressors (e.g., acidification, drought,
temperature extremes) have not been well studied. In a recent study of a mixture of VOCs
including ethanol and toluene on herbaceous plants, significant effects on seed production, leaf
water content, and photo synthetic efficiency were reported for some plant species.205

Research suggests an adverse impact of vehicle exhaust on plants, which has in some cases
been attributed to aromatic compounds and in other cases to nitrogen oxides.206'207'208 The
impacts of VOCs on plant reproduction may have long-term implications for biodiversity and
survival of native species near major roadways. Most of the studies of the impacts of VOCs on
vegetation have focused on short-term exposure, and few studies have focused on long-term
effects of VOCs on vegetation and the potential for metabolites of these compounds to affect
herbivores or insects.

5.4 Environmental Justice

EPA's 2016 "Technical Guidance for Assessing Environmental Justice in Regulatory
Analysis" provides recommendations on conducting the highest quality analysis feasible,
recognizing that data limitations, time and resource constraints, and analytic challenges will vary

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by media and regulatory context.XX11 When assessing the potential for disproportionately high and
adverse health or environmental impacts of regulatory actions on populations with potential EJ
concerns, the EPA strives to answer three broad questions: (1) Is there evidence of potential
environmental justice (EJ) concerns in the baseline (the state of the world absent the regulatory
action)? Assessing the baseline will allow the EPA to determine whether pre-existing disparities
are associated with the pollutant(s) under consideration (e.g., if the effects of the pollutant(s) are
more concentrated in some population groups). (2) Is there evidence of potential EJ concerns for
the regulatory option(s) under consideration? Specifically, how are the pollutant(s) and its effects
distributed for the regulatory options under consideration? And (3) do the regulatory option(s)
under consideration exacerbate or mitigate EJ concerns relative to the baseline? It is not always
possible to quantitatively assess these questions.

In this Chapter, we discuss the EJ impacts of the reduction of GHGs we anticipate from the
proposed GHG emission standards (Chapter 5.4.1). EPA did not select the proposed GHG
emission standards based on an analysis of disproportionate impacts of vehicle emissions, but we
view mitigation of disproportionate impacts of vehicle GHG emissions as one element of
protecting public health consistent with CAA section 202(a)(l)-(2). We also discuss potential
additional EJ impacts from the non-GHG (criteria pollutants and air toxics) emissions changes
we estimate would result from compliance with the proposed GHG emission standards (Chapter
5.4.2).

5.4.1 GHG Impacts

In 2009, under the Endangerment and Cause or Contribute Findings for Greenhouse Gases
Under Section 202(a) of the Clean Air Act ("Endangerment Finding"), the Administrator
considered how climate change threatens the health and welfare of the U.S. population. As part
of that consideration, she also considered risks to people of color and low-income individuals
and communities, finding that certain parts of the U.S. population may be especially vulnerable
based on their characteristics or circumstances. These groups include economically and socially
vulnerable communities; individuals at vulnerable life stages, such as the elderly, the very young,
and pregnant or nursing women; those already in poor health or with comorbidities; the disabled;
those experiencing homelessness, mental illness, or substance abuse; and/or Indigenous or
people of color dependent on one or limited resources for subsistence due to factors including
but not limited to geography, access, and mobility.

Scientific assessment reports produced over the past decade by the U.S. Global Change
Research Program (USGCRP),209'210 the Intergovernmental Panel on Climate Change
IPCC),211'212'213'214 and the National Academies of Science, Engineering, and Medicine215'216 add
more evidence that the impacts of climate change raise potential environmental justice concerns.
These reports conclude that poorer or predominantly non-White communities can be especially
vulnerable to climate change impacts because they tend to have limited adaptive capacities and
are more dependent on climate-sensitive resources such as local water and food supplies, or have
less access to social and information resources. Some communities of color, specifically
populations defined jointly by ethnic/racial characteristics and geographic location, may be
uniquely vulnerable to climate change health impacts in the U.S. In particular, the 2016 scientific

xxu "Technical Guidance for Assessing Environmental Justice in Regulatory Analysis." Epa.gov, Environmental
Protection Agency, https://www.epa.gOv/sites/production/files/2016-06/documents/ejtg_5_6_16_v5.l.pdf. (June
2016).

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assessment on the Impacts of Climate Change on Human Health217 found with high confidence
that vulnerabilities are place- and time-specific, life stages and ages are linked to immediate and
future health impacts, and social determinants of health are linked to greater extent and severity
of climate change-related health impacts. The GHG emission reductions from this proposal
would contribute to efforts to reduce the probability of severe impacts related to climate change.

5.4.1.1 Effects on Specific Populations of Concern

Individuals living in socially and economically disadvantaged communities, such as those
living at or below the poverty line or who are experiencing homelessness or social isolation, are
at greater risk of health effects from climate change. This is also true with respect to people at
vulnerable life stages, specifically women who are pre- and perinatal, or are nursing; in utero
fetuses; children at all stages of development; and the elderly. Per the Fourth National Climate
Assessment (NCA4), "Climate change affects human health by altering exposures to heat waves,
floods, droughts, and other extreme events; vector-, food- and waterborne infectious diseases;
changes in the quality and safety of air, food, and water; and stresses to mental health and well-
being."218 Many health conditions such as cardiopulmonary or respiratory illness and other
health impacts are associated with and exacerbated by an increase in GHGs and climate change
outcomes, which is problematic as these diseases occur at higher rates within vulnerable
communities. Importantly, negative public health outcomes include those that are physical in
nature, as well as mental, emotional, social, and economic.

To this end, the scientific assessment literature, including the aforementioned reports,
demonstrates that there are myriad ways in which these populations may be affected at the
individual and community levels. Individuals face differential exposure to criteria pollutants, in
part due to the proximities of highways, trains, factories, and other major sources of pollutant-
emitting sources to less-affluent residential areas. Outdoor workers, such as construction or
utility crews and agricultural laborers, who frequently are comprised of already at-risk groups,
are exposed to poor air quality and extreme temperatures without relief. Furthermore, individuals
within EJ populations of concern face greater housing, clean water, and food insecurity and bear
disproportionate economic impacts and health burdens associated with climate change effects.
They have less or limited access to healthcare and affordable, adequate health or homeowner
insurance. Finally, resiliency and adaptation are more difficult for economically disadvantaged
communities: They have less liquidity, individually and collectively, to move or to make the
types of infrastructure or policy changes to limit or reduce the hazards they face. They frequently
are less able to self-advocate for resources that would otherwise aid in building resilience and
hazard reduction and mitigation.

The assessment literature cited in EPA's 2009 and 2016 Endangerment and Cause or
Contribute Findings, as well as Impacts of Climate Change on Human Health, also concluded
that certain populations and life stages, including children, are most vulnerable to climate-related
health effects.219 The assessment literature produced from 2016 to the present strengthens these
conclusions by providing more detailed findings regarding related vulnerabilities and the
projected impacts youth may experience. These assessments - including the NCA4 and The
Impacts of Climate Change on Human Health in the United States (2016) - describe how
children's unique physiological and developmental factors contribute to making them
particularly vulnerable to climate change. Impacts to children are expected from heat waves, air
pollution, infectious and waterborne illnesses, and mental health effects resulting from extreme

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weather events. In addition, children are among those especially susceptible to allergens, as well
as health effects associated with heat waves, storms, and floods. Additional health concerns may
arise in low-income households, especially those with children, if climate change reduces food
availability and increases prices, leading to food insecurity within households.

The Impacts of Climate Change on Human Health217 also found that some communities of
color, low-income groups, people with limited English proficiency, and certain immigrant groups
(especially those who are undocumented) live with many of the factors that contribute to their
vulnerability to the health impacts of climate change. While difficult to isolate from related
socioeconomic factors, race appears to be an important factor in vulnerability to climate-related
stress, with elevated risks for mortality from high temperatures reported for Black or African
American individuals compared to White individuals after controlling for factors such as air
conditioning use. Moreover, people of color are disproportionately exposed to air pollution based
on where they live, and disproportionately vulnerable due to higher baseline prevalence of
underlying diseases such as asthma, so climate exacerbations of air pollution are expected to
have disproportionate effects on these communities.

Native American Tribal communities possess unique vulnerabilities to climate change,
particularly those impacted by degradation of natural and cultural resources within established
reservation boundaries and threats to traditional subsistence lifestyles. Tribal communities whose
health, economic well-being, and cultural traditions depend upon the natural environment will
likely be affected by the degradation of ecosystem goods and services associated with climate
change. The IPCC indicates that losses of customs and historical knowledge may cause
communities to be less resilient or adaptable.220 The NCA4 noted that while Indigenous peoples
are diverse and will be impacted by the climate changes universal to all Americans, there are
several ways in which climate change uniquely threatens Indigenous peoples' livelihoods and
economies.221 In addition, there can institutional barriers to their management of water, land, and
other natural resources that could impede adaptive measures.

For example, Indigenous agriculture in the Southwest is already being adversely affected by
changing patterns of flooding, drought, dust storms, and rising temperatures leading to increased
soil erosion, irrigation water demand, and decreased crop quality and herd sizes. The
Confederated Tribes of the Umatilla Indian Reservation in the Northwest have identified climate
risks to salmon, elk, deer, roots, and huckleberry habitat. Housing and sanitary water supply
infrastructure are vulnerable to disruption from extreme precipitation events.

NCA4 noted that Indigenous peoples often have disproportionately higher rates of asthma,
cardiovascular disease, Alzheimer's, diabetes, and obesity, which can all contribute to increased
vulnerability to climate-driven extreme heat and air pollution events. These factors also may be
exacerbated by stressful situations, such as extreme weather events, wildfires, and other
circumstances.

NCA4 and IPCC Fifth Assessment Report also highlighted several impacts specific to
Alaskan Indigenous Peoples. Coastal erosion and permafrost thaw will lead to more coastal
erosion, exacerbated risks of winter travel, and damage to buildings, roads, and other
infrastructure - these impacts on archaeological sites, structures, and objects that will lead to a
loss of cultural heritage for Alaska's Indigenous people. In terms of food security, the NCA4
discussed reductions in suitable ice conditions for hunting, warmer temperatures impairing the
use of traditional ice cellars for food storage, and declining shellfish populations due to warming

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and acidification. While the NCA also noted that climate change provided more opportunity to
hunt from boats later in the fall season or earlier in the spring, the assessment found that the net
impact was an overall decrease in food security.

In addition, the U.S. Pacific Islands and the indigenous communities that live there are also
uniquely vulnerable to the effects of climate change due to their remote location and geographic
isolation. They rely on the land, ocean, and natural resources for their livelihoods, but face
challenges in obtaining energy and food supplies that need to be shipped in at high costs. As a
result, they face higher energy costs than the rest of the nation and depend on imported fossil
fuels for electricity generation and diesel. These challenges exacerbate the climate impacts that
the Pacific Islands are experiencing. NCA4 notes that Indigenous peoples of the Pacific are
threatened by rising sea levels, diminishing freshwater availability, and negative effects to
ecosystem services that threaten these individuals' health and well-being.

5.4.2 Non-GHG Impacts

As discussed in Chapter 4 of the draft RIA, in addition to GHG emissions impacts, this
proposal would also impact emissions of non-GHGs (i.e., criteria and air toxic pollutants) from
vehicles and from upstream sources (e.g., EGUs and refineries). This section describes evidence
that communities with EJ concerns are disproportionately impacted by the non-GHG emissions
affected by this rule. Numerous studies have found that environmental hazards such as air
pollution are more prevalent in areas where people of color and low-income populations
represent a higher fraction of the population compared with the general population.222'223'224
Consistent with this evidence, a recent study found that most anthropogenic sources of PM2.5,
including industrial sources and light- and heavy-duty vehicle sources, disproportionately affect
people of color.225 In addition, compared to non-Hispanic Whites, some other racial groups
experience greater levels of health problems during some life stages. For example, in 2018-2020,
about 12 percent of non-Hispanic Black; 9 percent of non-Hispanic American Indian/Alaska
Native; and 7 percent of Hispanic children were estimated to currently have asthma, compared
with 6 percent of non-Hispanic White children.226 Nationally, on average, non-Hispanic Black
and Non-Hispanic American Indian or Alaska Native people also have lower than average life
expectancy based on 2019 data, the latest year for which CDC estimates are available.227

We discuss near-roadway issues in Chapter 5.4.2.1 and upstream sources in Chapter 5.4.2.2.
5.4.2.1 Near Roadway Analysis

As described in Section VI.B of this preamble, concentrations of many air pollutants are
elevated near high-traffic roadways. We recently conducted an analysis of the populations within
the CONUS living in close proximity to truck freight routes as identified in USDOT's FAF4.228
FAF4 is a model from the USDOT's Bureau of Transportation Statistics (BTS) and Federal
Highway Administration (FHWA), which provides data associated with freight movement in the
U.S.XXU1 Relative to the rest of the population, people living near FAF4 truck routes are more
likely to be people of color and have lower incomes than the general population. People living

XX111FAF4 includes data from the 2012 Commodity Flow Survey (CFS), the Census Bureau on international trade, as
well as data associated with construction, agriculture, utilities, warehouses, and other industries. FAF4 estimates the
modal choices for moving goods by trucks, trains, boats, and other types of freight modes. It includes traffic
assignments, including truck flows on a network of truck routes.
https://ops.fhwa.dot.gov/freight/freight_analysis/faf/.

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near FAF4 truck routes are also more likely to live in metropolitan areas. Even controlling for
region of the country, county characteristics, population density, and household structure, race,
ethnicity, and income are significant determinants of whether someone lives near a FAF4 truck
route.

We additionally analyzed other national databases that allowed us to evaluate whether homes
and schools were located near a major road and whether disparities in exposure may be occurring
in these environments. Until 2009, the U.S. Census Bureau's American Housing Survey (AHS)
included descriptive statistics of over 70,000 housing units across the nation and asked about
transportation infrastructure near respondents' homes every two years.229'XX1V We also analyzed
the U.S. Department of Education's Common Core of Data, which includes enrollment and
location information for schools across the U.S.230

In analyzing the 2009 AHS, we focused on whether a housing unit was located within 300
feet of a "4-or-more lane highway, railroad, or airport" (this distance was used in the AHS
analysis).xxv We analyzed whether there were differences between households in such locations
compared with those in locations farther from these transportation facilities.231 We included
other variables, such as land use category, region of country, and housing type. We found that
homes with a non-White householder were 22-34 percent more likely to be located within 300
feet of these large transportation facilities than homes with White householders. Homes with a
Hispanic householder were 17-33 percent more likely to be located within 300 feet of these large
transportation facilities than homes with non-Hispanic householders. Households near large
transportation facilities were, on average, lower in income and educational attainment and more
likely to be a rental property and located in an urban area compared with households more
distant from transportation facilities.

In examining schools near major roadways, we used the Common Core of Data (CCD) from
the U.S. Department of Education, which includes information on all public elementary and
secondary schools and school districts nationwide.XXV1 To determine school proximities to major
roadways, we used a geographic information system (GIS) to map each school and roadways
based on the U.S. Census's TIGER roadway file.232 We estimated that about 10 million students
attend schools within 200 meters of major roads, about 20 percent of the total number of public
school students in the U.S.XXVU About 800,000 students attend public schools within 200 meters
of primary roads, or about 2 percent of the total. We found that students of color were
overrepresented at schools within 200 meters of primary roadways, and schools within 200
meters of primary roadways had a disproportionate population of students eligible for free or

XX1V The 2013 AHS again included the "etrans" question about highways, airports, and railroads within half a block of
the housing unit but has not maintained the question since then.

xxv This variable primarily represents roadway proximity. According to the Central Intelligence Agency's World
Factbook, in 2010, the United States had 6,506,204 km of roadways, 224,792 km of railways, and 15,079 airports.
Highways thus represent the overwhelming majority of transportation facilities described by this factor in the AHS.
XXV1 http://nces.ed.gov/ccd/.

xxvn Here, "major roads" refer to those TIGER classifies as either "Primary" or "Secondary." The Census Bureau
describes primary roads as "generally divided limited-access highways within the Federal interstate system or under
state management." Secondary roads are "main arteries, usually in the U.S. highway, state highway, or county
highway system."

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reduced-price lunches.xxvm Black students represent 22 percent of students at schools located
within 200 meters of a primary road, compared to 17 percent of students in all U.S. schools.
Hispanic students represent 30 percent of students at schools located within 200 meters of a
primary road, compared to 22 percent of students in all U.S. schools.

We also reviewed existing scholarly literature examining the potential for disproportionate
exposure among people of color and people with low socioeconomic status (SES). Numerous
studies evaluating the demographics and socioeconomic status of populations or schools near
roadways have found that they include a greater percentage of residents of color, as well as lower
SES populations (as indicated by variables such as median household income). Locations in
these studies include Los Angeles, CA; Seattle, WA; Wayne County, MI; Orange County, FL;
and the State of California, and nationally.233'234'235'236'237'238'239 Such disparities may be due to
multiple factors.240'241'242'243'244

Additionally, people with low SES often live in neighborhoods with multiple stressors and
health risk factors, including reduced health insurance coverage rates, higher smoking and drug
use rates, limited access to fresh food, visible neighborhood violence, and elevated rates of
obesity and some diseases such as asthma, diabetes, and ischemic heart disease. Although
questions remain, several studies find stronger associations between air pollution and health in
locations with such chronic neighborhood stress, suggesting that populations in these areas may
be more susceptible to the effects of air pollution.245'246'247'248

Several publications report nationwide analyses that compare the demographic patterns of
people who do or do not live near major roadways.249'250'251'252'253'254 Three of these studies found
that people living near major roadways are more likely to be people of color or low in
SES.255'256'257 They also found that the outcomes of their analyses varied between regions within
the U.S. However, only one such study looked at whether such conclusions were confounded by
living in a location with higher population density and how demographics differ between
locations nationwide.258 In general, it found that higher density areas have higher proportions of
low-income residents and people of color. In other publications assessing a city, county, or state,
the results are similar.259'260

Two recent studies provide strong evidence that reducing emissions from heavy-duty vehicles
is extremely likely to reduce the disparity in exposures to traffic-related air pollutants, both using
NO2 observations from the recently launched TROPospheric Ozone Monitoring Instrument
(TROPOMI) satellite sensor as a measure of air quality, which provides the highest-resolution
observations heretofore unavailable from any satellite.261

One study evaluated NO2 concentrations during the COVID-19 lockdowns in 2020 and
compared them to NO2 concentrations from the same dates in 2019.262 That study found that
average NO2 concentrations were highest in areas with the lowest percentage of white
populations, and that the areas with the greatest percentages of non-white or Hispanic
populations experienced the greatest declines in NO2 concentrations during the lockdown. These
NO2 reductions were associated with the density of highways in the local area.

xxvmpor this analysis we analyzed a 200-meter distance based on the understanding that roadways generally
influence air quality within a few hundred meters from the vicinity of heavily traveled roadways or along corridors
with significant trucking traffic. See U.S. EPA, 2014. Near Roadway Air Pollution and Health: Frequently Asked
Questions. EPA-420-F-14-044.

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In the second study, NO2 measured from 2018-2020 was averaged by racial groups and
income levels in 52 large U.S. cities.263 Using census tract-level NO2, the study reported average
population-weighted NO2 levels to be 28% higher for low-income non-White people compared
with high-income white people. The study also used weekday-weekend differences and bottom-
up emission estimates to estimate that diesel traffic is the dominant source of NO2 disparities in
the studied cities.

Overall, there is substantial evidence that people who live or attend school near major
roadways are more likely to be of a non-White race, Hispanic, and/or have a low SES. We expect
communities near roads will benefit from the reduced tailpipe emissions of PM, NOx, SO2,
VOC, CO and mobile source air toxics from heavy-duty vehicles in this proposal. EPA is
considering how to better estimate the near-roadway air quality impacts of its regulatory actions
and how those impacts are distributed across populations. EPA requests comment on the EJ
analysis presented in this proposal.

5.4.2.2 Upstream Source Impacts

As described in Section V.B.2 of the preamble of this proposed rule, we expect some non-
GHG emissions reductions from sources related to refining petroleum fuels and increases in
emissions from EGUs, both of which would lead to changes in exposure for people living in
communities near these facilities. The EGU emissions increases become smaller over time
because of changes in the projected power generation mix as electricity generation uses less
fossil fuels; in 2055, the reductions in vehicle and refinery-related emissions of NOx, VOC,
PM2.5, and SO2 are larger than the EGU-related increases. Analyses of communities in close
proximity to EGUs have found that a higher percentage of communities of color and low-income
communities live near these sources when compared to national averages.264 Analysis of
populations near refineries also indicates there may be potential disparities in pollution-related
health risk from that source.265

Chapter 5 References

1 IPCC (2021): Summary for Policymakers. In: Climate Change 2021: The Physical Science Basis. Contribution of
Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson-
Delmotte, V., P. Zhai, A. Pirani, S.L. Connors, C. Pe'an, S. Berger, N. Caud, Y. Chen, L. Goldfarb, M.I. Gomis, M.
Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T.K. Maycock, T. Waterfield, O. Yelekc.i, R. Yu and B. Zhou
(eds.)]. Cambridge University Press

2 Ibid

3 Ibid

4 USGCRP (2018): Impacts, Risks, and Adaptation in the United States: Fourth National Climate Assessment,
Volume II [Reidmiller, D.R., C.W. Avery, D.R. Easterling, K.E. Kunkel, K.L.M. Lewis, T.K. Maycock, and B.C.
Stewart (eds.)]. U.S. Global Change Research Program, Washington, DC, USA, 1515 pp. doi: 10.7930/NCA4.2018.

5 IPCC (2018): Global Warming of 1.5 °C. An IPCC Special Report on the impacts of global warming of 1.5 °C
above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the
global response to the threat of climate change, sustainable development, and efforts to eradicate poverty [Masson-
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14 NIFC (National Interagency Fire Center). 2022. Total wildland fires and acres (1983-2020). Accessed November
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15 USGCRP (2018)

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17 EPA (2009) Metabolically-derived ventilation rates: A revised approach based upon oxygen consumption rates.
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18 U.S. EPA Integrated Science Assessment for Particulate Matter (Final Report, 2019). U.S. Environmental
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19 Foos, B.; Marty, M.; Schwartz, J.; Bennet, W.; Moya, J.; Jarabek, A.M.; Salmon, A.G. (2008) Focusing on
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20 EPA (2006) A Framework for Assessing Health Risks of Environmental Exposures to Children. EPA,
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22 U.S. EPA. America's Children and the Environment. Available at:
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31 U.S. EPA. Integrated Science Assessment (ISA) for Particulate Matter (Final Report, 2019). U.S. Environmental
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32 U.S. EPA. Supplement to the 2019 Integrated Science Assessment for Particulate Matter (Final Report, 2022).
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33 U.S. EPA. Integrated Science Assessment (ISA) for Particulate Matter (Final Report, 2019). U.S. Environmental
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34U.S. EPA. Integrated Science Assessment (ISA) for Particulate Matter (Final Report, 2019). U.S. Environmental
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399

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37 U.S. EPA. Integrated Science Assessment for Oxides of Nitrogen - Health Criteria (2016 Final Report). U.S.
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38 U.S. EPA, (2010). Integrated Science Assessment for Carbon Monoxide (Final Report). U.S. Environmental
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51 NTP (National Toxicology Program). 2016. Report on Carcinogens, Fourteenth Edition.; Research Triangle Park,
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52 International Agency for Research on Cancer (IARC). (1999). Re-evaluation of some organic chemicals,
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53 U.S. EPA (1991). Integrated Risk Information System File of Acetaldehyde. This material is available
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54 U.S. EPA. (2003). Integrated Risk Information System File of Acrolein. Research and Development, National
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55 Appleman, L.M., R.A. Woutersen, and V.J. Feron. (1982). Inhalation toxicity of acetaldehyde in rats. I. Acute and
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56Myou, S.; Fujimura, M.; Nishi K.; Ohka, T.; and Matsuda, T. (1993). Aerosolized acetaldehyde induces
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58 U.S. EPA. (2003). Integrated Risk Information System File of Acrolein. Research and Development, National
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59 International Agency for Research on Cancer (IARC). (2021). Monographs on the Identification of Carcinogenic
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60 U.S. EPA. (2003). Integrated Risk Information System File of Acrolein. Office of Research and Development,
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61 U.S. EPA. (2003). Integrated Risk Information System File of Acrolein. Office of Research and Development,
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62 U.S. EPA. (2003). Toxicological review of acrolein in support of summary information on Integrated Risk
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63 U.S. EPA. (2003). Toxicological review of acrolein in support of summary information on Integrated Risk
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64 Morris JB, Symanowicz PT, Olsen JE, et al. (2003). Immediate sensory nerve-mediated respiratory responses to
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65 U.S. EPA. (2009). Graphical Arrays of Chemical-Specific Health Effect Reference Values for Inhalation
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66U.S. EPA. (2000). Integrated Risk Information System File for Benzene. This material is available electronically
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67 International Agency for Research on Cancer. (1982). IARC monographs on the evaluation of carcinogenic risk of
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68 Irons, R.D.; Stillman, W.S.; Colagiovanni, D.B.; Henry, V.A. (1992). Synergistic action of the benzene metabolite
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69U.S. EPA. (2000). Integrated Risk Information System File for Benzene. This material is available electronically
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70 International Agency for Research on Cancer (IARC, 2018. Monographs on the evaluation of carcinogenic risks
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71 NTP (National Toxicology Program). 2016. Report on Carcinogens, Fourteenth Edition.; Research Triangle Park,
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72 Aksoy, M. (1989). Hematotoxicity and carcinogenicity of benzene. Environ. Health Perspect. 82: 193-197. EPA-
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73 Goldstein, B.D. (1988). Benzene toxicity. Occupational medicine. State of the Art Reviews. 3:541-554.

74Rothman, N, G.L. Li, M. Dosemeci, W.E. Bechtold, G.E. Marti, Y.Z. Wang, M. Linet, L.Q. Xi, W. Lu, M.T.
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75 U.S. EPA (2002). Toxicological Review of Benzene (Noncancer Effects). Environmental Protection Agency,
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76 Qu, O.; Shore, R.; Li, G.; Jin, X.; Chen, C.L.; Cohen, B.; Melikian, A.; Eastmond, D.; Rappaport, S.; Li, H.; Rupa,
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77 Qu, Q., R. Shore, G. Li, X. Jin, L.C. Chen, B. Cohen, et al. (2002). Hematological changes among Chinese
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78Lan, Qing, Zhang, L., Li, G., Vermeulen, R., et al. (2004). Hematotoxically in Workers Exposed to Low Levels of
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79 Turtletaub, K. W. and Mani, C. (2003). Benzene metabolism in rodents at doses relevant to human exposure from
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81 Corti, M; Snyder, CA. (1996) Influences of gender, development, pregnancy and ethanol consumption on the
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82 McKinney P. A.; Alexander, F.E.; Cartwright, R.A.; et al. (1991) Parental occupations of children with leukemia
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83 Keller, KA; Snyder, CA. (1986) Mice exposed in utero to low concentrations of benzene exhibit enduring changes
in their colony forming hematopoietic cells. Toxicology 42:171-181.

84 Keller, KA; Snyder, CA. (1988) Mice exposed in utero to 20 ppm benzene exhibit altered numbers of
recognizable hematopoietic cells up to seven weeks after exposure. Fundam Appl Toxicol 10:224-232.

85 Corti, M; Snyder, CA. (1996) Influences of gender, development, pregnancy and ethanol consumption on the
hematotoxicity of inhaled 10 ppm benzene. Arch Toxicol 70:209-217.

86 U. S. EPA. (2002). Toxicological Review of Benzene (Noncancer Effects). National Center for Environmental
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87 Ford, AM; Pombo-de-Oliveira, MS; McCarthy, KP; MacLean, JM; Carrico, KC; Vincent, RF; Greaves, M. (1997)
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88U.S. EPA. (2002). Health Assessment of 1,3-Butadiene. Office of Research and Development, National Center for
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89U.S. EPA. (2002) "Full IRIS Summary for 1,3-butadiene (CASRN 106-99-0)" Environmental Protection Agency,
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90 International Agency for Research on Cancer (IARC). (1999). Monographs on the evaluation of carcinogenic risk
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91 International Agency for Research on Cancer (IARC). (2008). Monographs on the evaluation of carcinogenic risk
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92 NTP (National Toxicology Program). 2016. Report on Carcinogens, Fourteenth Edition.; Research Triangle Park,
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93 International Agency for Research on Cancer (IARC). (2012). Monographs on the evaluation of carcinogenic risk
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94 U.S. EPA. (2002). "Full IRIS Summary for 1,3-butadiene (CASRN 106-99-0)" Environmental Protection Agency,
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96 U.S. EPA. (1991). Integrated Risk Information System File for Ethylbenzene. This material is available
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97 U.S. EPA (2017). IRIS Assessment Plan for Ethylbenzene. EPA/635/R-17/332. This document is available
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98 U.S. EPA (2022). IRIS Program Outlook. June, 2022. This material is available electronically at:
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99 California OEHHA, 2007. Adoption of a Unit Risk Value for Ethylbenzene. This material is available
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100 California OEHHA, 2008. Technical Supporting Document for Noncancer RELs, Appendix D3. This material is
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101 EPA. Integrated Risk Information System. Formaldehyde (CASRN 50-00-0)
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102NTP (National Toxicology Program). 2016. Report on Carcinogens, Fourteenth Edition.; Research Triangle Park,
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104 IARC Monographs on the Evaluation of Carcinogenic Risks to Humans Volume 100F (2012): Formaldehyde.
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107 Beane Freeman, L. E.; Blair, A.; Lubin, J. H.; Stewart, P. A.; Hayes, R. B.; Hoover, R. N; Hauptmann, M. 2009.
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110Hauptmann, M„ Stewart P. A.; Lubin J. H.; Beane Freeman, L. E.; Hornung, R. W.; Herrick, R. F.; Hoover, R.
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111 ATSDR. 1999. Toxicological Profile for Formaldehyde, U.S. Department of Health and Human Services (HHS),
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112 ATSDR. 2010. Addendum to the Toxicological Profile for Formaldehyde. U.S. Department of Health and Human
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113 IPCS. 2002. Concise International Chemical Assessment Document 40. Formaldehyde. World Health
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115 NRC (National Research Council). 2011. Review of the Environmental Protection Agency's Draft IRIS
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117 U.S. EPA. IRIS Toxicological Review of Formaldehyde-Inhalation (Interagency Science Consultation Draft,
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118 https://www.nationalacademies.org/our-work/review-of-epas-2021-draft-formaldehyde-assessment
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120 U. S. EPA. 1998. Toxicological Review of Naphthalene (Reassessment of the Inhalation Cancer Risk),
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121 U. S. EPA. (1998). Toxicological Review of Naphthalene (Reassessment of the Inhalation Cancer Risk),
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122U. S. EPA. (1998). Toxicological Review of Naphthalene (Reassessment of the Inhalation Cancer Risk),
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123 Oak Ridge Institute for Science and Education. (2004). External Peer Review for the IRIS Reassessment of the
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125 NTP (National Toxicology Program). 2016. Report on Carcinogens, Fourteenth Edition.; Research Triangle Park,
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126 International Agency for Research on Cancer (IARC). (2002). Monographs on the Evaluation of the
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127 U. S. EPA. (1998). Toxicological Review of Naphthalene, Environmental Protection Agency, Integrated Risk
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128 U. S. EPA. (1998). Toxicological Review of Naphthalene. Environmental Protection Agency, Integrated Risk
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129 ATSDR. Toxicological Profile for Naphthalene, 1-Methylnaphthalene, and 2-Methylnaphthalene (2005).
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133 McDonald, B.C.; McBride, Z.C.; Martin, E.W.; Harley, R.A. (2014) High-resolution mapping of motor vehicle
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135 Kimbrough, S.; Palma, T.; Baldauf, R.W. (2014) Analysis of mobile source air toxics (MSATs)—Near-road
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148 Laden, F.; Hart, J.E.; Smith, T.J.; Davis, M.E.; Garshick, E. (2007) Cause-specific mortality in the unionized
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149 Peters, A.; von Klot, S.; Heier, M.; Trentinaglia, I.; Hormann, A.; Wichmann, H.E.; Lowel, H. (2004) Exposure
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150 Zanobetti, A.; Stone, P.H.; Spelzer, F.E.; Schwartz, J.D.; Coull, B.A.; Suh, H.H.; Nearling, B.D.; Mittleman,
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151 Adar, S.; Adamkiewicz, G.; Gold, D.R.; Schwartz, J.; Coull, B.A.; Suh, H. (2007) Ambient and
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152 HEI Panel on the Health Effects of Long-Term Exposure to Traffic-Related Air Pollution (2022) Systematic
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153 Boogaard, H.; Patton. A.P.; Atkinson, R.W.; Brook, J.R.; Chang, H.H.; Crouse, D.L.; Fussell, J.C.; Hoek, G.;
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155 Salam, M.T.; Islam, T.; Gilliland, F.D. (2008). Recent evidence for adverse effects of residential proximity to
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156 Sun, X.; Zhang, S.; Ma, X. (2014) No association between traffic density and risk of childhood leukemia: a
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157 Raaschou-Nielsen, O.; Reynolds, P. (2006). Air pollution and childhood cancer: a review of the epidemiological
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158 Boothe, VL.; Boehmer, T.K.; Wendel, A.M.; Yip, F.Y. (2014) Residential traffic exposure and childhood
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159 National Toxicology Program (2019) NTP Monograph n the Systematic Review of Traffic-related Air Pollution
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163 Wu, J.; Wilhelm, M.; Chung, J.; et al. (2011). Comparing exposure assessment methods for traffic-related air
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164 Stenson, C.; Wheeler, A.J.; Carver, A.; et al. (2021) The impact of traffic-related air pollution on child and
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167 Eckel. S.P.; Berhane, K.; Salam, M.T.; et al. (2011). Residential Traffic-related pollution exposure and exhaled
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171 McConnell, R.; Islam, T.; Shankardass, K.; et al. (2010). Childhood incident asthma and traffic-related air
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172 Islam, T.; Urban, R.; Gauderman, W.J.; et al. (2011). Parental stress increases the detrimental effect of traffic
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173 Clougherty, J.E.; Levy, J.I.; Kubzansky, L.D.; et al. (2007). Synergistic effects of traffic-related air pollution and
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174 Chen, E.; Schrier, H.M.; Strunk, R.C.; et al. (2008). Chronic traffic-related air pollution and stress interact to
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175 U.S. EPA (2021). Estimation of Population Size and Demographic Characteristics among People Living Near
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176 EPA. (2011) Exposure Factors Handbook: 2011 Edition. Giapter 16. Online at
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190 See Section 169(a) of the Clean Air Act.

191 64 FR 35714, July 1, 1999.

192 62 FR 38680-38681, July 18, 1997.

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233 Marshall, J.D. (2008) Environmental inequality: air pollution exposures in California's South Coast Air Basin.

234 Su, J.G.; Larson, T.; Gould, T.; Cohen, M.; Buzzelli, M. (2010) Transboundary air pollution and environmental
justice: Vancouver and Seattle compared. GeoJournal 57: 595-608. doi:10.1007/sl0708-009-9269-6

235 Chakraborty, J.; Zandbergen, P.A. (2007) Children at risk: measuring racial/ethnic disparities in potential
exposure to air pollution at school and home. J Epidemiol Community Health 61: 1074-1079.

doi: 10.1136/jech. 2006.054130

236 Green, R.S.; Smorodinsky, S.; Kim, J. J.; McLaughlin, R.; Ostro, B. (20042004) Proximity of California public
schools to busy roads. Environ Health Perspect 112: 61-66. doi:10.1289/ehp.6566

237 Wu, Y; Batterman, S.A. (2006) Proximity of schools in Detroit, Michigan to automobile and truck traffic. J
Exposure Sci & Environ Epidemiol. doi:10.1038/sj.jes.7500484

238 Su, J.G.; Jerrett, M.; de Nazelle, A.; Wolch, J. (2011) Does exposure to air pollution in urban parks have
socioeconomic, racial, or ethnic gradients? Environ Res 111: 319-328.

239 Jones, M.R.; Diez-Roux, A.; Hajat, A.; et al. (2014) Race/ethnicity, residential segregation, and exposure to
ambient air pollution: The Multi-Ethnic Study of Atherosclerosis (MESA). Am J Public Health 104: 2130-2137.
[Online at: https://doi.org/10.2105/AJPH.2014.302135.]

240 Depro, B.; Timmins, C. (2008) Mobility and environmental equity: do housing choices determine exposure to air
pollution? Duke University Working Paper.

241 Rothstein, R. The Color of Law: A Forgotten History of How Our Government Segregated America. New York:
Liveright, 2018.

242 Lane, H.J.; Morello-Frosch, R.; Marshall, J.D.; Apte, J.S. (2022) Historical redlining is associated with present-
day air pollution disparities in US Cities. Environ Sci & Technol Letters 9: 345-350. DOI: [Online at:
https://doi.org/10.1021/acs.estlett.lc01012]

243 Ware, L. (2021) Plessy's legacy: the government's role in the development and perpetuation of segregated
neighborhoods. RSF: The Russel Sage Foundation Journal of the Social Sciences, 7:92-109. DOI: DOI:
10.7758/RSF.2021.7.1.06.

244 Archer, D.N. (2020) "White Men's Roads through Black Men's Homes": advancing racial equity through
highway reconstruction. Vanderbilt Law Rev 73: 1259.

245 Clougherty, J.E.; Kubzansky, L.D. (2009) A framework for examining social stress and susceptibility to air
pollution in respiratory health. Environ Health Perspect 117: 1351-1358. Doi: 10.1289/ehp.0900612

246 Clougherty, J.E.; Levy, J.I.; Kubzansky, L.D.; Ryan, P.B.; Franco Suglia, S.; Jacobson Canner, M.; Wright, R.J.
(2007) Synergistic effects of traffic-related air pollution and exposure to violence on urban asthma etiology.

Environ Health Perspect 115: 1140-1146. doi: 10.1289/ehp.9863

247 Finkelstein, M.M.; Jerrett, M.; DeLuca, P.; Finkelstein, N; Verma, D.K.; Chapman, K.; Sears, M.R. (2003)
Relation between income, air pollution and mortality: a cohort study. Canadian Med Assn J 169: 397-402.

248 Shankardass, K.; McConnell, R.; Jerrett, M.; Milam, J.; Richardson, J.; Berhane, K. (2009) Parental stress
increases the effect of traffic-related air pollution on childhood asthma incidence. Proc Natl Acad Sci 106: 12406-
12411. doi:10.1073/pnas.0812910106

249Rowangould, G.M. (2013) A census of the U.S. near-roadway population: public health and environmental
justice considerations. Transportation Research Part D; 59-67.

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250 Tian, N; Xue, J.; Barzyk. T.M. (2013) Evaluating socioeconomic and racial differences in traffic-related metrics
in the United States using a GIS approach. J Exposure Sci Environ Epidemiol 23: 215-222.

251 CDC (2013) Residential proximity to major highways - United States, 2010. Morbidity and Mortality Weekly
Report 62(3): 46-50.

252 Clark, L.P.; Millet, D.B., Marshall, J.D. (2017) Changes in transportation-related air pollution exposures by race-
ethnicity and socioeconomic status: outdoor nitrogen dioxide in the United States in 2000 and 2010. Environ
Health Perspect https://doi.org/10.1289/EHP959.

253 Mikati, I.; Benson, A.F.; Luben, T.J.; Sacks, J.D.; Richmond-Bryant, J. (2018) Disparities in distribution of
particulate matter emission sources by race and poverty status. Am J Pub Health
https://ajph.aphapublications.org/doi/abs/10.2105/AJPH. 2017.304297?journalCode=ajph.

254 Alotaibi, R.; Bechle, M.; Marshall, J.D.; Ramani, T.; Zietsman, J.; Nieuwenhuijsen, M.J.; Khreis, H. (2019)
Traffic related air pollution and the burden of childhood asthma in the continuous United States in 2000 and 2010.
Environ International 127: 858-867. https://www.sciencedirect.com/science/article/pii/S0160412018325388.

255 Tian, N.; Xue, J.; Barzyk. T.M. (2013) Evaluating socioeconomic and racial differences in traffic-related metrics
in the United States using a GIS approach. J Exposure Sci Environ Epidemiol 23: 215-222.

256 Rowangould, G.M. (2013) A census of the U.S. near-roadway population: public health and environmental
justice considerations. Transportation Research Part D; 59-67.

257 CDC (2013) Residential proximity to major highways - United States, 2010. Morbidity and Mortality Weekly
Report 62(3): 46-50.

258 Rowangould, G.M. (2013) A census of the U.S. near-roadway population: public health and environmental
justice considerations. Transportation Research Part D; 59-67.

259 Pratt, G.C.; Vadali, M.L.; Kvale, D.L.; Ellickson, K.M. (2015) Traffic, air pollution, minority, and socio-
economic status: addressing inequities in exposure and risk. Int J Environ Res Public Health 12: 5355-5372.
http://dx.doi.org/10.3390/ijerphl20505355.

260 Sohrabi, S.; Zietsman, J.; Khreis, H. (2020) Burden of disease assessment of ambient air pollution and premature
mortality in urban areas: the role of socioeconomic status and transportation. Int J Env Res Public Health

doi: 10.3390/ijerphl7041166.

261 TROPospheric Ozone Monitoring Instrument (TROPOMI) is part of the Copernicus Sentinel-5 Precursor
satellite.

262 Kerr, G.H.; Goldberg, D.L.; Anenberg, S.C. (2021) COVID-19 pandemic reveals persistent disparities in nitrogen
dioxide pollution. PNAS 118. [Online at https://doi.org/10.1073/pnas.2022409118]

263 Demetillo, M.A.; Harkins, C.; McDonald, B.C.; et al. (2021) Space-based observational constraints on N02 air
pollution inequality from diesel traffic in major US cities. Geophys Res Lett 48, e2021GL094333. [Online at
https://doi.org/10.1029/2021GL094333]

264 See 80 FR 64662, 64915-64916 (October 23, 2015).

265 U.S. EPA (2014). Risk and Technology Review—Analysis of Socio-Economic Factors for Populations Living
Near Petroleum Refineries. Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina.
January.

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Chapter 6 Economic and Other Impacts

This chapter discusses potential impacts of the proposed rule on vehicle sales including
potential shifts among modes and classes of vehicles, and between domestic and foreign sales. It
also discusses the acceptance of ZEVs by HD purchasers and the potential for rebound effects on
VMT. This chapter then discusses the potential impacts of the proposed rule on employment.
Finally, this chapter discusses the impacts of the proposed rule on U.S. oil imports and electricity
consumption.

6.1 Impact on Sales, Fleet Turnover, Mode Shift, Class Shift, and Domestic Production
6.1.1 Vehicle Sales and Fleet Turnover

The effects of the proposed CO2 emission standards on HD vehicle sales will depend, at least
in part, on the extent to which purchasers consider fuel, maintenance, and repair savings
associated with the proposed HD GHG Phase 3 program in their purchase decisions. Our
analyses indicate that, while heavy-duty ZEVs and associated EVSE, as applicable, will be more
expensive to purchase than comparable ICE vehicles, ZEVs will be less expensive to operate and
maintain than comparable ICE vehicles. The more these savings are considered, the smaller the
impact on sales due to an increase in the price of the vehicle. In addition, if the savings
considered by a purchaser outweigh the increase in the price of the vehicle and EVSE, which we
show is possible with most ZEVs (see DRIA Chapter 2.9.4.2), sales of that vehicle may increase.

In addition to effects on total sales of HD vehicles, perceptions about post-regulation vehicles
and cost differences between pre- and post-regulation vehicles (both upfront and operational
costs) may lead to an increase in the sale of ICE vehicles before the proposed standards become
effective in order to avoid possible cost, quality, or other changes due to the regulation, a
phenomenon called "pre-buy." These are vehicles that are purchased earlier than would have
happened in the absence of the standards. Another reason pre-buy might occur is due to
purchaser beliefs about the availability of their vehicle type of choice in the post-regulation
market. For example, if purchasers think that they might not be able to get the HD ICE vehicle
they want after the proposed regulation is promulgated, they may pre-buy a HD ICE vehicle.1 We
expect that purchasers' consideration of the lower operational costs of ZEVs, as well as the
federal vehicle and battery tax credits in the IRA, would mitigate possible pre-buy by reducing
the perceived purchase price or lifetime operational costs difference of a new, post-rule ZEV
compared to a new pre- or post-rule ICE vehicle. Additionally, pre-buy, to the extent it might
occur, could be mitigated in other ways, including by reducing the higher upfront cost of post-
regulation vehicles, by purchasers considering the lower operational costs of post-regulation
vehicles when making their purchase decisions, or through the phasing in of the proposed
standards. Pre-buy may also be mitigated by educating purchasers on the benefits of ZEV
ownership (for example, reduced operating costs) or on charging and hydrogen refueling
infrastructure technology and availability. Our proposed standards will increase purchaser
exposure to ZEVs, as well as incentivize manufacturers and dealers to educate HD vehicle
purchasers on ZEVs, including the benefits of ZEVs, accelerating the reduction of purchaser risk

1 It should be noted that the HD TRUCS model used in this rulemaking to analyze ZEV technology matched
performance capabilities of ZEVs to an existing ICE vehicle for each use case where the ZEV vehicles are
technologically feasible.

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aversion (see Chapter 6.2). Local and federal actions investing in charging infrastructure,
including the BIL and IRA, will lead to reduced uncertainty surrounding ZEV ownership, likely
further mitigating possible pre-buy. For more information on purchaser acceptance of HD ZEVs,
see Chapter 6.2. For more information on the charging and hydrogen refueling infrastructure
analysis in this proposed rule, see Chapters 1.6, 1.8, and 2.6. The proposed standards do not
mandate the use of a specific technology, and EPA anticipates that a compliant fleet under the
proposed standards would include a diverse range of technologies, including ICE and ZEV
technologies. In addition, the phasing-in of the proposed standards, which do not eliminate any
specific technology from the market, would allow ample time for purchasers to make decisions
about their vehicle of choice.

A counter to pre-buy is "low-buy," a scenario in which there would be a decrease in HD
vehicle sales after the regulation becomes effective. In a low-buy scenario, sales of HD vehicles
would decrease in the months after the regulation becomes effective, compared to what would
have happened in the absence of the regulation, due to purchasers either pre-buying or delaying a
planned purchase. Low-buy may be due directly to pre-buy, where vehicle purchases that would
have been made in the months after the effective date of the new emission standards are pulled
forward to before the effective date of the new emission standards. Alternatively, low-buy may
be due to purchasers delaying the purchase of a new vehicle due to the new emissions standards,
for example because of increased costs or uncertainty related to the regulated vehicles. If pre-buy
is smaller than low-buy, to the extent they both might occur, this would lead to reduced fleet
turnover, at least in the short-term.11 The older trucks would remain in use longer than they would
have in the absence of the new emission standards. This would lead to lower emission reductions
than we estimate would be achieved as a result of the proposal. If pre-buy is larger than low-buy,
short-term fleet turnover would increase; fleets would be, on average, comprised of newer model
year vehicles. Though these new vehicles are expected to have lower emissions than the vehicles
they are replacing, and emission reductions would be expected to be larger than under a scenario
where low-buy exceeds pre-buy, emission reductions would still be lower than we estimated
would be achieved as a result of the proposed emission standards. Under a situation where low-
buy matches pre-buy, we would also expect lower emission reductions than estimated, and
emission reductions would likely be somewhere between the two relative pre-buy /low-buy
scenarios discussed above. Low-buy, to the extent it might occur, could also be mitigated under
the same circumstances described above for pre-buy. Both pre-buy and low-buy, if they were to
occur, are short-term phenomena.

Analysis of previously promulgated EPA HD emission standards indicates that where pre- or
low-buy is seen, the magnitude has been small.111 EPA recently contracted with Eastern Research

II Fleet turnover refers to the pace at which new vehicles are purchased and older vehicles are retired. A slower fleet
turnover means older vehicles are kept on the road longer, and the fleet is older on average. A faster fleet turnover
means that the fleet is younger, on average.

III For example, Lam, T., and Bausell, C. "Strategic Behaviors Toward Environmental Regulation: A Case of
Trucking Industry." Contemporary Economic Policy 25(1): 3-13. 2007, Rittenhouse, K., and Zaragoza-Watkins,M.
"Anticipation and Environmental Regulation." Journal of Environmental Economics and Management 89: 255-277.
2018, and an unpublished report by Harrison, D., Jr., and LeBel, M. "Customer Behavior in Response to the 2007
Heavy-Duty Engine Emission Standards: Implications for the 2010 NOX Standard." NERA Economic Consulting.
2008. For EPA's summary on these studies, see the EPA peer review study U.S. Environmental Protection Agency.
"Analysis of Heavy-Duty Vehicle Sales Impacts Due to New Regulation." EPA-420-R-21-013. 2021.

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Group, inc. (ERG) to complete a literature review on research that estimates sales impacts, as
well as to conduct original research to estimate sales impacts for previous EPA HD vehicle rules
on pre- and low-buy for HD vehicles. This work suggested that pre- and low-buy effects may
occur for up to a year before or after a regulation is implemented, if they occur at all.1,1V The
resulting analysis examined the effect of four HD regulations, those that became effective in
2004, 2007, 2010 and 2014, on the sales of Class 6, 7 and 8 vehicles over the twelve months
before and after each standard/ For the purposes of this discussion, we will call these the 2004
rule, 2007 rule, 2010 rule and 2014 rule. The 2004, 2007 and 2010 rules focused on reducing
criteria pollutant emissions. The 2014 rule (the HD GHG Phase 1 rule promulgated in 2014)
focused on reducing GHG emissions. The report finds little evidence of sales impacts for Class 6
and 7 vehicles. For Class 8 vehicles, evidence of pre-buy was found before the 2010 rule's
implementation and for only one month before the 2014 rule's implementation dates, and
evidence of low-buy was found after the 2002, 2007 and 2010 rules' implementation dates. The
report findings, however, do suggest that the range of possible results include a lower bound of
zero, i.e., no pre-buy or low-buy due to EPA rules.V1

While it is instructive that the ERG report found little to no pre-buy or low-buy effects due to
our HD rules, EPA does not believe the approach to estimate a change in the sales of HD
vehicles before and after the promulgation of a rule due to the cost of that rule (as was done in
the ERG report) should be used to estimate sales effects from this proposed rule for three main
reasons."1 First, most of the statistically significant results were estimated using data from
criteria pollutant rules (the 2002, 2004 and 2007 rules), which are not appropriate for use in
estimating effects from GHG rules. This is due to differences in how costs and benefits are
accrued between criteria pollutant and GHG rules, which may lead to differences in how HD
vehicle buyers react to a regulation. For example, the 2014 rule reduced GHG emissions, and had
lower estimates of associated technology costs relative to the criteria pollutant rules, and
compliance with the GHG rule was associated with fuel savings. We also expect operating
savings due to this proposed rule, as described in Chapter 3.4.

Second, the sales effects were estimated as a function of the average change in the estimated
technology cost of a HD vehicle for each vehicle class due to the specific rule under
consideration (for example, the 2007 rule or the 2014 rule). However, unlike the criteria
pollutant rules, there were numerous pathways for compliance with the 2014 rule, which led to

https://cfpub.epa.gov/si/si_public_pra_view.cfm?dirEntryID=349838&Lab=OTAQ, or the recently published EPA

Heavy-Duty 2027 rule at Docket ID EPA-HQ-2019-0555

lv This report will be referred to as the ERG report in the rest of this discussion.

v The 2004 rule, "Final Rule for Control of Emission of Air Pollution From Highway Heavy-Duty Engines", was
finalized in 1997. The 2007 and 2010 rules were finalized as phase-ins in the "Final Rule for Control of Emissions
of Air Pollution from 2004 and Later Model Year Heavy-Duty Highway Engines and Vehicles; Revision of Light-
Duty On-Board Diagnostics Requirements" in 2000. The 2014 GHG rule, "Final Rule for Phase 1 Greenhouse
House Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles,"
was finalized in 2011. These rules can be found on the EPA website https://www.epa.gov/regulations-emissions-
vehicles-and-engines/regulations-emissions-commercial-trucks-and-buses-heavy.

V1 The ERG report includes statistically significant results of no effect for pre-buy on the 2002 rule, as well as results
where no effect cannot be ruled out for pre-buy on the 2007, 2010 and 2014 rules, and for low-buy on the 2002,
2010 and 2014 rules.

vu See the Chapter 10 in RIA for the HD 2027 rule for an example of how we might estimate potential impacts of a
HD regulation on vehicle sales, including pre-buy and low-buy, using the approach introduced in the ERG report. 88
FR 14296. January 24, 2023.

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uncertainty in the estimate of cost due to that rule. As this estimated change in cost is what was
used to estimate the effect of the rule on pre-buy and low-buy, there is some uncertainty about
the results of the pre-buy and low-buy sales effects from the 2014 rule.

Third, the approach outlined in the ERG report was estimated only using data from HD ICE
vehicles (for example, cost of compliance due to adding technology to a HD engine). The
research and methods did not include any data from the production, sale or purchase of HD
ZEVs.

Though there is uncertainty related to the costs used in the 2014 rule analysis, the results of
the ERG report, combined with the literature review completed for the report, indicate that there
is little evidence of pre-buy or low-buy associated with GHG rules. This is supported by data
from the U.S. Bureau of Economic Analysis, which shows that sales of heavy-weight trucks
were fairly consistently increasing from the end of 2009 through the end of 2015 (with a slight
downward blip between the middle and end of 2012).VU1 Altogether, this suggests that there was
likely little to no pre- or low-buy due to the 2014 GHG rule.

If finalized, this proposed rule is expected to lead to a decrease in total HD highway fleet
emissions, though this decrease would happen gradually as the HD fleet turns over.lx This is
because the fraction of the total on-highway HD vehicle fleet that are new ZEVs would initially
be a small portion of the entire HD market. As more ZEVs are sold, and as older HD ICE
vehicles are retired, greater emission reductions would occur. If ZEV uptake occurs faster than
predicted, emission reductions would happen faster than estimated. If, assuming no change in
total fleet vehicle miles traveled (VMT), the VMT attributed to ZEVs is less than would have
been attributed to a HD ICE vehicle it is displacing, emission reductions would happen slower
than estimated. In addition, if there is pre-buy or low-buy associated with this proposed rule,
emission reductions would be less than estimated as well. This is because, under pre-buy
conditions, the pre-bought vehicles are less likely to be ZEVs, though they are likely to be less
polluting than the HD vehicle they are replacing (if it is a replacement purchase) due to more
stringent HD emission standards for new engines and vehicles. Under low-buy, older more
polluting vehicles would remain in use longer than they otherwise would in the absence of new
standards. EPA expects this proposed rule to result in little pre-buy or low-buy, if it occurs at all.

6.1.2 Mode Shift

Another potential, though unlikely, effect of this proposed regulation is mode shift. Mode
shift would occur if goods that would normally be shipped by HD vehicles are shipped by
another method (e.g., rail, boat, air) due to the proposed emission standards. EPA does not
expect this proposed rule to result in a transportation mode shift. Generally, shipping cargo via
truck is more expensive per ton-mile than barge or rail, and less expensive than air.2'3 This is due
to many factors, not the least of which is labor costs (each truck has at least one driver). Even
though trucking is more expensive than rail or marine on a ton-mile basis, it is a very attractive
transportation alternative for several reasons: shipping via truck is generally faster and more
convenient than rail or marine, trucks can reach more places, and trucks may be less constrained

vm The graph of monthly, seasonally adjusted heavy weight truck sales from the Bureau of Economic Analysis can
be found at: https://fred.stlouisfed.org/series/HTRUCKSSAAR

K See Preamble Section V and DRIA Chapter 4.4 for details on estimated HD emissions effects due to this proposed
rule.

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by available infrastructure than barge or rail. In addition, shipping via truck does not require
trans-shipments (transferring from one mode to another, for example to deliver cargo to or from
the port or rail yard), and it allows partial deliveries at many locations. This speed, infrastructure
availability, and delivery flexibility make trucking the transportation solution of choice for many
kinds of cargo across most distances. As a result, smaller shipments of higher-valued goods (e.g.,
consumer goods) tend to be transported by air or truck, while larger shipments of lower-valued
goods (e.g., raw materials) tend to go via rail or barge.2'4

Studies of intermodal freight shifts, such as Comer et al. (2010) or Bushnell and Hughes
(2019), focus on changes in cost per ton-mile as a potential source of transportation mode shift.2'4
Comer et al. note, for instance, that fuel consumption "depend[s] on the type of freight being
moved, route characteristics, transport speed, and locomotive/truck characteristics."2 Bushnell
and Hughes estimate that increased fuel prices for truck transportation lead to small substitutions
between truck and rail for small or large shipments, and higher shifts for intermediate-sized
shipments.4 The findings from this study suggest that the variation in the kinds and values of
goods shipped by different modes likely result in only a small amount of mode shift in response
to a change in operating cost (e.g., fuel prices). However, due to data availability, this study
approximates freight rates with fuel costs, assumes shipping distances using different modes are
the same, and mostly does not consider transportation availability constraints affecting some
modes in some regions. These limitations may distort the effects they estimate.

A mode shift study EPA carried out in 2012 in the context of new sulfur limits for fuel used in
large ships operating on the Great Lakes may help address some of these limitations.3 The
methodology used a combination of geospatial modeling and freight rate analysis to examine the
impact of an increase in ship operating costs. While the focus of the study was transportation
mode shift away from marine and toward land, it noted that truck transportation is far more
expensive than both rail and marine on a ton-mile basis.x It also shows that even a large
percentage increase in marine fuel costs did not raise freight rates by a similar percentage,
because fuel costs are only part of total operating costs. In the case of truck transportation,
operating costs are a much smaller portion of total costs. The results of this study combined with
the others cited in this section indicate that changing the cost of truck transportation is unlikely to
create mode shift.

Whether shippers switch to a different transportation mode for freight depends not only on the
cost per mile of the shipment (i.e., freight rate), but also the value of the shipment, the speed of
transport needed for shipment (for example, for non-durable goods), and the availability of
supporting infrastructure (e.g., rail lines, highways, waterways). Shifting from HD vehicles to
other modes of transportation may occur if the cost of shipping goods by truck increases relative
to shipping by other modes, and it is feasible to switch the shipment from truck to another mode.
This proposed rule is expected to reduce operational costs for trucks, and we do not think mode
shift from HD vehicles to a different mode of transportation is a likely outcome of this proposed
regulation.

6.1.3 Class Shift

x Figure 1-5 in U.S. EPA Office of Transportation and Air Quality. "Economic Impacts of the Category 3 Marine
Rule on Great Lakes Shipping." EPA-420-R-12-005. 2012.

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Class shift is also a possible effect of this proposed rule; however, vehicle classes among
which shifting would feasibly occur are all subject to this proposed rule. Class shift would occur
if purchasers shift their purchases from one class of vehicle to another class of vehicle due to
differences in cost among vehicle types. We expect that class shifting, if it does occur, would be
limited. The proposed emission standards are projected to lead to an increase in the incremental
upfront cost per vehicle for many classes of vehicles across both vocational and tractor
categories before accounting for the IRA vehicle and battery tax credits. After accounting for
these credits, our estimates show that this upfront increase in cost is reduced, and in fact, we
estimate that some vocational vehicles and tractor ZEVs have lower or equivalent upfront costs
compared to comparable ICE vehicles.X1 Furthermore, the upfront costs for vocational vehicles
and tractors would be offset by operational cost savings.

Another reason EPA believes class shift would be limited, if it occurs, is that HD vehicles are
typically configured and purchased to perform a specific function. For example, a concrete mixer
is purchased to transport concrete, or a combination tractor is purchased to move freight with the
use of a trailer. In addition, a purchaser in need of a specific vocational vehicle, such as a bus,
box truck or street sweeper, would not be able to shift the purchase to a vehicle with a less
stringent emission standard, such as the optional custom chassis standards for emergency
vehicles, recreational vehicles, or mixed use (nonroad) type vehicles, and still meet their needs.
The purchaser makes decisions based on many attributes of the vehicle, including the gross
vehicle weight rating or gross combined weight rating of the vehicle, which in part determines
the amount of freight or equipment that can be carried. Due to this, it may not be feasible for
purchasers to switch to other vehicle classes. If a limited amount of shifting were to occur, we
would expect negligible emission impacts (compared to those emission reductions estimated to
occur as a result of the proposed emission standards) because the vehicle classes that would be
feasibly "switched" are all subject to this proposed rule.

6.1.4 Domestic Production

The proposed standards are not expected to provide incentives for manufacturers to shift
between domestic and foreign production. This is because the standards apply to any vehicles
sold in the U.S. regardless of where they are produced. If foreign manufacturers already have
relatively more expertise in satisfying the requirements of the standards, there may be some
initial incentive for foreign production. However, offsetting this potential effect, and given
increasing global interest in reducing vehicle emissions, specifically through the use of ZEVs, as
domestic manufacturers produce vehicles with reduced emissions (including ZEVs) the
opportunity for domestic manufacturers to sell in other markets might increase. To the extent that
the requirements of this proposed rule might lead to application and use of technologies that
other countries may seek now or in the future, developing this capacity for domestic producers
now may provide some additional ability to serve those markets.

As discussed in Preamble Section l.C, and DRIA Chapter 1.3.2, IRA section 13502,
"Advanced Manufacturing Production Credit," contains battery tax credit incentives that are
impacted by the location of production and may encourage domestic production of ZEV vehicles

X1 For more information on estimated purchaser costs due to this proposed rule, see Preamble Section IV.D or DRIA
Chapter 3.4.

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or components. As described in Section IV of the Preamble and Chapter 3.1 of the DRIA, a
portion of these tax incentives are included in our cost analysis for the proposed rule.

6.2 Purchaser Acceptance

This proposed rule is expected to lead to an increase in the adoption of HD BEVs and FCEVs
for most of the HD vehicle types for MYs 2027 and beyond (see preamble Section II or the
DRIA Chapter 2 for details). As explained in Chapter 2.8, although HD ZEVs in general have
higher upfront costs than comparable ICE vehicles, our cost analysis shows that this incremental
upfront cost difference would be partially or fully offset by a combination of the federal vehicle
purchase tax credits and battery tax credits for HD ZEVs that are available through MY 2032, as
well as the operational cost savings. For the vehicle types for which we propose new CO2
emission standards, we expect that the ZEV will have a lower total cost of ownership when
compared to a comparable ICE vehicle (even after considering the upfront cost of purchasing the
associated EVSE for a BEV), due to the expected cost savings in fuel, maintenance, and repair
over the life of the HD ZEV when compared to a comparable ICE vehicle. See Section IV of the
preamble or Chapter 3 of this DRIA for more information on the estimated costs of this proposed
rule.

Potential savings in operating costs appear to offer HD vehicle buyers strong incentives to pay
higher upfront prices for vehicles, such as ZEVs, that feature technology or equipment that
reduces operating costs. Economic theory suggests a normally functioning competitive market
would lead HD vehicle manufacturers to incorporate technologies that contribute to lower net
costs into the vehicles they offer, and lead buyers to purchase them willingly. Nevertheless, as
discussed extensively in the HD Phase 2 rule,xu an "energy efficiency gap" or "energy paradox"
has existed, where available technologies that would reduce the total cost of ownership for the
vehicle (when evaluated over their expected lifetimes using conventional discount rates) have not
been widely adopted, or the adoption is relatively slow, despite their potential to repay buyers'
initial investments rapidly.

This proposed rule would be expected to lead to reduced operating costs, especially for
purchasers of HD ZEVs. Given EPA's assessment for this proposal showing significant
reductions in operating costs from compliance with the proposed standards, economic theory
would suggest that the market should deliver those savings, and increase ZEV adoption, without
EPA's proposed standards. When it comes to HD ZEVs, we are seeing increasing demand for,
and increasing investment in, ZEV technology in the absence of the proposed standards/111 It is
possible that EPA's reference case is underestimated, and adoption of ZEVs, and other
technologies, will occur more rapidly than EPA predicts in this proposal.X1V

Economic research offers several possible explanations for why the prospect of these apparent
savings might not lead HD manufacturers and buyers to adopt technologies that would be
expected to reduce operating costs, though existing research focuses on adoption of ICE
technology that results in decreased fuel costs. Explanations include constraints on access to
capital for investment, imperfect or asymmetrical information about the new technology (for
example, real-world operational cost savings, durability, or performance), uncertainty about

xn See 81 FR 73859, October 25, 2016
xm See Preamble I.C.

Xlv As discussed elsewhere, EPA requests comment on our reference case.

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supporting infrastructure (for example, ease of charging a BEV), uncertainty about the resale
market, and first-mover disadvantages for manufacturers. Below, we discuss how some of these
may impact the adoption of HD ZEVs.

We expect that adoption rates of HD ZEVs would be impacted by buyers taking advantage of
existing incentives, specifically the IRA vehicle tax credit,xv to lower the upfront costs for
purchasers of HD ZEVs. The extent to which buyers consider the cost savings of purchasing a
ZEV over an HD ICE vehicle in their purchase decision, mainly observed through operational
cost savings, will also impact the adoption of ZEVs. One reason purchasers may not consider the
full, or even a portion of, operational cost savings of a ZEV over a comparable ICE vehicle, is
due to uncertainty, e.g., uncertainty about future fuel and electricity prices.XV1 Adoption may be
affected by additional areas of uncertainty as well. In a working paper by Bae, et al. (2022),5 the
authors report the results of interviews conducted in 2018 and 2019 with eighteen HD fleet
operators in California on their perspectives on viable alternative fuel options over the next
decade and beyond, as well as what motivators or barriers exist to adopting those alternatives.
Though electric, hydrogen, compressed natural gas and hybrid options were generally seen as
viable in the 2030's, operators reported concerns related to functional unsuitability of electric
options, uncompetitive upfront costs of hydrogen, and unpromising support from state
government. In addition, for electric and hydrogen options specifically, fleet operators expressed
concern that infrastructure might not be ready to support electric or hydrogen adoption, that there
is an uncertain return on investment, and that there is a perceived unavailability of vehicles. We
note that significant changes have already occurred since these interviews were conducted,
including an increase in the number of HD ZEV models available in the market, and the
important incentives provided in the BIL and the IRA which provide support for development
and purchase of heavy-duty ZEVs, including reducing the costs of purchasing ZEVs and
reducing the costs of ZEV refueling infrastructure.

As purchasers learn more about ZEV technologies, and as the penetration of the technology
increases, the exposure to ZEV technologies in the real world will reduce uncertainty related to
viability or durability of the vehicles and the availability of supporting infrastructure. As of 2022,
many HD vehicle manufacturers have developed electric vehicles, and companies with large
distribution needs, including UPS, FedEx, DHL, Walmart, Anheuser-Busch Co., Amazon and
PepsiCo Inc., have expressed significant interest in using HD ZEVs.xvu As discussed in
Preamble Section I.C, there have been public announcements by these and other companies,
demonstrating increasing commitment to expanding their electric fleets. Though increasing
penetration of HD ZEVs will continue to happen regardless of the proposed standards, these
proposed standards are expected to help accelerate the process, incentivizing manufacturers to
educate purchasers on the benefits of HD ZEVs.

Another reason purchasers may not consider the full, or even a portion of, operational cost
savings of a ZEV over a comparable ICE vehicle is if a principal-agent problem exists, causing

xv The IRA battery tax credit is also expected to reduce upfront costs for purchasers, although it is a tax credit for
battery manufacturers, not purchasers. We expect vehicle manufacturers to reduce the price of their vehicles in
accordance with their ability to take advantage of this battery tax credit in order to remain competitive in the market.
XV1 See Chapter 6.1.1 for further discussion on how uncertainty related to ZEVs may affect vehicles sales.
xvu International Energy Association. Global EV Outlook 2021. April 2021. Available online at:
https://iea.blob.core.windows.net/assets/ed5f4484-f556-4110-8c5c-4ede8bcba637/GlobalEVOutlook2021.pdf.

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split incentives.™11 A principal-agent problem would exist if truck operators (agents) and truck
purchasers who are not also operators (agents) value operational cost savings, higher purchase
prices, or availability or cost of EVSE installation differently, which could lead to differences in
purchase decisions between truck operators and truck purchasers. For example, a HD vehicle
purchaser may not be directly responsible for the future fuel costs of the vehicle they purchase,
or the person who would be responsible for those fuel costs may not be involved in the purchase
decision. In this case, truck operators may place a higher value on the potential savings in
operating costs over the lifetime of a vehicle and give less weight to the increase in upfront cost
that may be associated with a ZEV purchase, whereas a truck purchaser may weigh higher
upfront costs more heavily than possible operational cost savings. Such potential split incentives,
or market failures, could lead to lower ZEV adoption rates than we are estimating in this
proposal, which may reduce the environmental benefit of the proposed emission standards. Other
examples of this might include if a purchaser values charging or fueling infrastructure, either the
cost of installation or the availability, differently than the operator. The direction of the effect in
this case would depend on who was responsible for the cost of the infrastructure installation, or
who places more value on the availability of widespread infrastructure.

We also expect purchasing decisions to be affected by purchasers' impressions of BEV
charging and FCEV fueling infrastructure support and availability, perceptions of the
comparisons of quality and durability of the different HD powertrains, and resale value of the
vehicle. Another factor that may affect adoption of ZEVs is purchasers' uncertainty about the
technology, both with respect to ZEVs, as well as with new technology applied to ICE
vehicles.X1X As ZEVs become more affordable and ubiquitous on the roadways, we expect
uncertainty related to this technology to wane. Nonetheless, such potential market failures could
lead to lower ZEV adoption rates than we are estimating in this proposal, which may reduce the
non-GHG emission reductions estimated in this proposal.

Though ZEVs are being introduced in the HD market, their adoption is currently low, and
their representation in the resale market is almost non-existent. There is uncertainty surrounding
the ability of the original owners to recover their original investment. In addition, the
uncertainties mentioned above for new HD ZEV buyers, including those related to payback,
durability, and infrastructure, also exist for purchasers of used ZEVs. However, some
uncertainties will likely be reduced. For example, the used ZEV market will mature more slowly
than the new ZEV market, giving time for future ZEV owners to learn about the technology and
for the supporting infrastructure to mature. As more used ZEVs enter the market, uncertainty
related to ZEVs and the supporting infrastructure will shrink.

We expect that the IRA vehicle and battery tax credits, as well as purchasers' consideration of
the lower operational costs of ZEVs, will mitigate any possible pre-buy by reducing the
perceived purchase price or lifetime operational costs difference of a new, post-rule ZEV
compared to a new pre- or post-rule ICE vehicle. We expect this would increase purchaser
willingness to purchase a new ZEV. When purchasers are educated on charging or refueling
infrastructure technology and availability, both as it stands at the time of possible purchase, as

xvm A principal-agent problem happens when there is a conflict in priorities (split incentives) between a "principal,"
or the owner of an asset, and an "agent," or the person to whom control of the asset has been delegated, such as a
manager or HD vehicle operator.

X1X As mentioned in Preamble I.F, some manufacturers are including maintenance in leasing agreements. This could
reduce uncertainty related to new technology.

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well as plans for future availability, uncertainty related to operating a new ZEV decreases, and
we expect that this would lead to an increase in ZEV adoption as well.

The adoption of ZEVs is also affected by manufacturers. In order for someone to purchase a
HD ZEV for their specific needs, the vehicle that meets those needs must exist in the market. In
manufacturing, especially in situations where developing, implementing, or marketing a new
technology requires large initial investment, a "first-mover disadvantage" may exist. The "first-
mover disadvantage" occurs when the "first-mover" pays a higher proportion of the costs of
developing, implementing, or marketing a new technology and loses the long-term advantage
when other businesses move into that market. However, there could also be "dynamic increasing
returns" to adopting new technologies, wherein the value of a new technology may depend on
how many other companies have adopted the technology. Additionally, there can be research and
development synergies when many companies work on the same technologies at the same time,
assuming there's a reason to innovate at the same time.

Standards such as those proposed in this rule can create conditions under which companies
invest in major innovations. As discussed in Preamble Section I.C, HD manufacturers are already
producing some ZEV models and investing in the development and production of additional
models, and large companies that rely on HD vehicles have already expressed an interest in
purchasing HD ZEV technology. This rule is expected to provide incentives to manufacturers to
produce more HD ZEV models, as well as to invest in educating purchasers on the benefits of
ZEVs, as well as on infrastructure. For example, Daimler Trucks North America, Volvo Trucks,
Navistar, PACCAR, and Cummins are a few of the HD companies investing in ZEV
infrastructure and supporting the education of ZEV purchasers.6

Purchaser acceptance of BEVs and FCEVs is difficult to estimate. The data and research
needed to definitively discuss what affects whether HD buyers will adopt BEVs or FCEVs is
limited.xx We expect that, similar to the decisions made by LD vehicle buyers, part of the
decision on whether to purchase a BEV or FCEV over an ICE vehicle may depend on the
relative price of the vehicles, the amount to which purchasers account for fuel, and other
operating cost savings in their purchase decision, and on understanding (or perceived
understanding) of the charging or refueling infrastructure. In addition, more unique to the HD
market, we expect that understanding of the technical suitability of the vehicle to its intended
application may impact the decision of whether to purchase an HD ZEV or ICE vehicle. For
example, a long-haul Class 8 tractor will have different needs than a local delivery Class 8
tractor.

In our analysis of the proposed standards, we account for some of the factors impacting HD
ZEV adoption, including uncertainty about weight, component (e.g., battery) sizing and
infrastructure availability. Our analysis applies oversize factors for batteries to account for
temperature effects, potential battery degradation and more; we sized batteries for the 90th
percentile of estimated VMT; and we sized EVSE to assume that vehicles' batteries could be
fully recharged overnight. In addition, we cap the ZEV adoption rate for each vehicle type to be
no more than 80 percent. For more detail on the constraints we considered and included, see
Preamble Sections II.D, HE and II.F For this proposal, we developed a method to project

** EPA has recently completed an in-depth, peer reviewed, study of adoption of LD BEVs. See "Literature Review
of U.S. Consumer Acceptance of New Personally Owned Light Duty Plug-in Electric Vehicles" at

https://cfpnb.epa.gov/si/si public record_report.cfm?Lab=OTAQ&dirEntryId=3S346S for more information.

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adoption rates of BEVs and FCEVs in the HD vehicle market after considering methods in the
literature. Our adoption function, and methods considered and explored in the formulation of the
method used in this proposal, are described in DRIA Chapter 2.7.9. As stated there, given
information currently available, and our experience with the HD vehicle industry, total cost of
ownership and payback are key metrics to the HD vehicle industry. The projected ZEV adoption
rate schedule used in our model is increased in 2032 compared to 2027 because ZEV technology
will be more mature. Fleet owners and drivers will have had more exposure to ZEV technology
in 2032 compared to 2027, which may work to alleviate concerns related to ZEVs (for example,
concerns of reliability) and result in a lower impression of risk of these newer technologies. In
addition, infrastructure to support ZEV technologies will have had more time to expand and
mature, further supporting increased HD ZEV adoption rates.

NREL published a study in early 2022 indicating that medium- and heavy-duty ZEVs can
reach cost parity with (diesel) ICE vehicles by 2035.7 Specifically, they estimate that battery
electric vehicles will become cost competitive for smaller trucks and short-haul heavy trucks,
and fuel cell vehicles will become cost competitive for long-haul heavy trucks by 2035.

Reaching cost parity is expected to increase adoption of HD ZEVs, though NREL also makes the
point that continued charging and refueling infrastructure improvements are needed to further
support adoption. ICCT released a study in 2022 that states that three segments in the HD
market, urban buses, urban delivery vehicles, and short-haul tractors, are good candidates for
early ZEV adoption, and can reach 100% ZEV sales as early as 2030.8 'XX1 In addition, in their
"The State of Sustainable Fleets" report, Gladstein, Neandross & Associates report that HD ZEV
demand exceeds availability even though battery and infrastructure costs remain high.9 The
authors state that "a combination of public and private investment, aggressive sustainability
commitments, and zero-emission regulations" are leading to an accelerated transition to clean
vehicles and fuels.

In summary, EPA recognizes that businesses that operate HD vehicles are under competitive
pressure to reduce operating costs, which should encourage HD vehicle buyers to identify and
rapidly adopt cost-effective technologies that reduce the total cost of ownership. Outlays for
labor and fuel generally constitute the two largest shares of HD vehicle operating costs,
depending on the price of fuel, distance traveled, type of HD vehicle, and commodity transported
(if any), so businesses that operate HD vehicles face strong incentives to reduce these costs.
However, EPA also recognizes that there is uncertainty related to ZEVs that may impact the
adoption of this technology even though it reduces operating costs. Markets for both new and
used HD vehicles may face these problems, although it is difficult to assess empirically the
degree to which they do. We expect the proposed Phase 3 standards, if finalized, will help
overcome such barriers by incentivizing the development of ZEV technologies and the education
of HD vehicle purchasers on ZEV benefits and infrastructure.

6.3 VMT Rebound

The "rebound effect" refers to the increase in demand for an energy service when the cost of
the energy service is reduced due to efficiency improvements.10'11'™11 In the context of HD

XX1 For more information on the ICCT study, see Preamble Section I.C. 1.

xxii For a discussion of the wide range of definitions found in the literature, see Appendix D: Discrepancy in
Rebound Effect Definitions, in EERA (2014), "Research to Inform Analysis of the Heavy-Duty vehicle Rebound

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vehicles, this has been interpreted as more intensive vehicle use, resulting in an increase in liquid
fuel consumption, in response to increased ICE vehicle fuel efficiency. Although much of this
possible vehicle use increase is likely to take the form of an increase in the number of miles
vehicles are driven, it can also take the form of increases in the loaded operating weight of a
vehicle or altering routes and schedules in response to improved fuel efficiency of the HD ICE
vehicle. More intensive use of those HD ICE vehicles consumes fuel and generates emissions,
which reduces fuel savings and avoided emissions that would otherwise be expected to result
from increasing fuel efficiency of HD ICE vehicles.

Unlike the LD vehicle rebound effect, there is little published literature on the HD vehicle
rebound effect, and all of it focuses on ICE vehicles and liquid fuel efficiency. Winebrake et al.
(2015) suggests that vocational trucks and tractor trailers have a rebound effect of essentially
zero. Leard et al. (2015) estimate that tractor trailers have a rebound effect of 30 percent, while
vocational vehicles have a 10 percent rebound rate.12 Patwary et al. (2021) estimated that the
average rebound effect of the U.S. road freight sector is between about 7 to 9 percent, though
their study indicated that rebound has increased over time.13 This is slightly smaller than the
value found by Leard et al. (2015) for the similar sector of tractor trailers.

In the HD GHG Phase 2 final rule RIA, we estimated a 5 percent rebound effect for
vocational trucks and for tractor trailers, and a 10 percent rebound effect for HD pick-up trucks
and vans, with those rebound effects being applied to ICE vehicles. These estimates were
determined using the most recent studies in HD rebound at the time, as well as in response to
comments submitted on the proposed HD GHG Phase 2 rule. As mentioned above, all the current
research focuses on VMT rebound of HD ICE vehicles. We do not have data that operational
cost savings of switching from an ICE vehicle to a ZEV will affect the VMT of that vehicle, nor
do we have data on how changing fuel prices might affect VMT of ZEVs over time. Therefore,
we are not estimating any VMT rebound due to this rule.

6.4 Employment Impacts

This section discusses potential employment impacts of the proposed regulation. If the U.S.
economy is at full employment, we expect that even a large-scale environmental regulation is
unlikely to have a noticeable impact on aggregate net employment. Instead, labor would
primarily be reallocated from one productive use to another, as workers transition away from
jobs that are less environmentally protective and towards jobs that are more environmentally
protective. Affected sectors may nevertheless experience transitory effects as workers change
jobs. Some workers may retrain or relocate in anticipation of new requirements or require time to
search for new jobs, while shortages in some sectors or regions could bid up wages to attract
workers. These adjustment costs can lead to local labor disruptions. Even if the net change in the
national workforce is small, localized reductions in employment may adversely impact
individuals and communities just as localized increases may have positive impacts. If the
economy is operating at less than full employment, economic theory does not clearly indicate the
direction or magnitude of the net impact of environmental regulation on employment; it could
cause either a short-run net increase or short-run net decrease as discussed further below.

Effect," and Excerpts of Draft Final Report of Phase 1 under EPA contract EP-C-13-025. (Docket ID: EPA-HQ-
OAR-2014-0827). See also Greening, L.A., Greene, D.L., Difiglio, C., 2000, "Energy efficiency and consumption
— the rebound effect — a survey," Energy Policy, 28, 389-401.

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6.4.1 Background and Literature

Economic theory of labor demand indicates that employers affected by environmental
regulation may change their demand for different types of labor in different ways. They may
increase their demand for some types, decrease demand for other types, or maintain demand for
still other types. The uncertain direction of labor impacts is due to the different channels by
which regulations affect labor demand. A variety of conditions can affect employment impacts of
environmental regulation, including baseline labor market conditions, employer and worker
characteristics, industry, and region. In general, the employment effects of environmental
regulation are difficult to disentangle from other economic changes, including, for example, the
impacts of the coronavirus pandemic on labor markets, the general state of the macroeconomy,
as well as a myriad of business decisions that affect employment. These changes have variable
employment impacts, both over time and across regions and industries. In light of these
difficulties, we look to economic theory to provide a constructive framework for approaching
these assessments and for better understanding the inherent complexities in such assessments.

In this chapter, we describe three ways employment at the firm level might be affected by
changes in a firm's production costs due to environmental regulation: a factor-shift effect, in
which post-regulation production technologies may have different labor intensities than their pre-
regulation counterparts; a demand effect, caused by higher production costs increasing market
prices and decreasing demand; and a cost effect, caused by additional environmental protection
costs leading regulated firms to increase their use of inputs, including labor, to produce the same
level of output. These effects are outlined in a paper by Morgenstern et al. (2002), which
provides the theoretical foundation for EPA's analysis of the impacts of this regulation on
labor.14 Due to data limitations, EPA is not quantifying the impacts of the final regulation on
firm-level employment for affected companies, although we acknowledge these potential
impacts. Instead, we describe possible effects on employment due to the transition to ZEVs, and
then discuss factor-shift, demand, and cost employment effects for the regulated sector at the
industry level.

Additional papers approach employment effects through similar frameworks. Berman and Bui
(2001)15 model two components that drive changes in firm-level labor demand: output effects
and substitution effects.xxm Deschenes (2018)16 describes environmental regulations as requiring
additional capital equipment for pollution abatement that does not increase labor productivity.
For an overview of the neoclassical theory of production and factor demand, see Chapter 9 of
Layard and Walters' Microeconomic Theory.17 Ehrenberg and Smith (2000)18 describe how, at
the industry level, labor demand is more likely to be responsive to regulatory costs if: (1) the
elasticity of labor demand is high relative to the elasticity of labor supply, and (2) labor costs are
a large share of total production costs.

Arrow, Cropper, et al. (1996)19 state that, in the long run, environmental regulation is
expected to cause a shift of employment among employers rather than affect the general
employment level. Even if they are mitigated by long-run market adjustments to full
employment, many regulatory actions have transitional effects in the short run.20'21 These
movements of workers in and out of jobs in response to environmental regulation are potentially
important distributional impacts of interest to policy makers. Of particular concern are

xxm Berman and Bui (2001) also discuss a third component, the impact of regulation on factor prices, but conclude
that this effect is unlikely to be important for large competitive factor markets, such as labor and capital.

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transitional job losses experienced by workers operating in declining industries, exhibiting low
migration rates, or living in communities or regions where unemployment rates are high.

Workers affected by changes in labor demand due to regulation may experience a variety of
impacts including job gains or involuntary job loss and unemployment. Compliance with
environmental regulation can result in increased demand for the inputs or factors (including
labor) used in the production of environmental protection. However, the regulated sector
generally relies on revenues generated by their other market outputs to cover the costs of
supplying increased environmental quality, which can lead to reduced demand for labor and
other factors of production used to produce the market output. Workforce adjustments in
response to decreases in labor demand can be costly to firms as well as workers, so employers
may choose to adjust their workforce over time through natural attrition or reduced hiring, rather
than incur costs associated with job separations (see, for instance, Curtis (2018)22 and Hafstead
and Williams (2018)23).

As suggested in this discussion, the overall employment effects of environmental regulation
are difficult to estimate. Estimation is difficult due to the multitude of small changes that occur
in different sectors related to the regulated industry, both upstream and downstream, or in sectors
producing substitute or complimentary products. In the following sections, we qualitatively
discuss potential impacts of the proposed rule on the vehicle manufacturing, battery production,
and charging and refueling infrastructure sectors due to the transition to ZEVs, and due to the
factor-shift, demand and cost effects. Then, we briefly discuss potential impacts on additional
sectors such as the retail firms selling products transported by HD trucks and the petroleum
refining industry.

6.4.2 Potential Employment Impacts of the Transition to Zero-Emission Vehicles

The increasing adoption of BEVs and FCEVs in the market is likely to affect both the number
and the nature of employment in the HD manufacturing and related sectors, such as providers of
battery charging and refueling infrastructure. Over time, as ZEVs become a greater portion of the
new HD vehicle fleet, the kinds of jobs in HD manufacturing are expected to change. For
instance, there will be no need for engine and exhaust system assembly for BEVs, while many
assembly tasks will instead involve electrical rather than mechanical fitting. Batteries represent a
significant portion of the manufacturing content of an electrified vehicle, and some automakers
are likely to purchase the cells, if not pre-assembled modules or packs, from suppliers whose
employment will thereby be affected. Employment will be affected in building and maintaining
battery charging or fuel cell refueling infrastructure needed to support the ever-increasing
number of ZEVs on the road. For much of these effects, there is not enough data to quantitatively
assess how employment might change as a function of the increased electrification expected to
result under the proposed standards.

A recent report from the Seattle Jobs Initiative identified sectors most strongly associated with
LD ICE and BEV production, where electrical equipment and manufacturing and other electrical
equipment and component manufacturing were said to be associated with LD BEV production
(including batteries), and motor vehicle manufacturing, motor vehicle body and trailer
manufacturing, and motor vehicle parts manufacturing were associated with both LD BEV and
ICE production.28 These sectors also include HD vehicle manufacturing. The Employment
Requirements Matrix (ERM) provided by the U.S. Bureau of Labor Statistics (BLS) provides
direct estimates of employees per $1 million in expenditures for a total of 202 aggregated sectors

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that roughly correspond to the 4-digit NAICS code level, and provides data from 1997 through
2021.24 These estimates are averages, covering all the activities in these sectors and may not be
representative of the labor effects when expenditures are required for specific activities, or when
manufacturing processes change due to compliance activities in such a way that labor intensity
changes. For instance, the ratio of workers to production cost for the motor vehicle body and
trailer manufacturing sector represents this ratio for all motor vehicle body and trailer
manufacturing activities, and not just for production processes related to emission reductions
compliance activities. In addition, these estimates do not include changes in sectors that supply
these sectors, such as steel or electronics producers. However, examining that data over time
suggests general employment trends in light- and heavy-duty manufacturing. Using this
historical data, we can see that the workers per $1 million in sales for all five of these sectors
has, generally, decreased over time. Over time, the amount of labor needed in the motor vehicle
industry has changed: automation and improved methods have led to significant productivity
increases. The BLS ERM, for instance, provides estimates that, in 1997, about 1.2 workers in the
Motor Vehicle Manufacturing sector were needed per $1 million, (in 2020$), while, for 2021 this
figure had decreased to only 0.5 workers per $1 million (2020$) by 2021 (in 2020$). Though the
two sectors mainly associated with BEV manufacturing, electrical equipment manufacturing and
other electrical equipment and component manufacturing show an increase in recent years.

Figure 6-1 shows the estimates of employment per $1 million of expenditure for each sector
for each data source, adjusted to 2020 dollars using the U.S. Bureau of Economic Analysis Gross
Domestic Product Implicit Price Deflator retrieved from the Federal Reserve Bank of St. Louis.
The values are adjusted to remove effects of imports through the use of a ratio of domestic
production to domestic sales of 0.81.XX1V

M
m
if)
c

CO
w

s»_

o
§

4.000
3.500

a ooo

2.500
2,000
1500
1000
0.500
0.000

Year

Electrical equipment manufacturing

— « Other electrical equipment and component manufacturing

— Motor vehicle manufactunng

Motor vehicla body and trailer manufacturing

— — — Motor vehicle parts manufacturing

Figure 6-1 Workers per million dollars in sales, adjusted for domestic production.

XX1V To estimate the proportion of domestic production affected by the change in sales, we use data from WardsAuto
for total car and truck production in the U.S. compared to total car and truck sales in the U.S. Over the period 2009-
2021, the proportion averages 83 percent. From 2016-2021, the proportion average is slightly lower, at 81 percent.

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Though most of the research on employment effects associated with the shift from ICE to
ZEVs is focused on the light-duty market, many of the same ideas transfer to the HD market as
well. Generally, research is not consistent on the expected direction or magnitude of change in
employment as new ICE vehicle sales are replaced with new BEV or fuel cell vehicle sales. The
BlueGreen Alliance states that although battery electric vehicles have fewer parts than their ICE
counterparts, there is potential for job growth in electric vehicle component manufacturing,
including batteries, electric motors, regenerative braking systems and semiconductors, and
manufacturing those components in the US can lead to an increase in jobs.25 They go on to state
that if the US does not become a major producer for these components, there is risk of job loss.

In anticipation of shifts in the skills necessary for workers in the automobile industry due to a
greater share of electric vehicles, the International Union, United Automobile, Aerospace and
Agricultural Implement Workers of America (UAW) states that re-training programs will be
needed to prepare workers that might be displaced by the shift to the new technology.26
Volkswagen states that labor requirements for ICE vehicles are about 70% higher than their
electric counterpart, but these changes in employment intensities in the manufacturing of the
vehicles can be offset by shifting to the production of new components, for example batteries or
battery cells.27 Research from the Seattle Jobs initiative indicates that employment in a collection
of sectors related to both battery electric and ICE vehicle manufacturing is expected to grow
slightly through 2029.28 Though most of these statements are specifically referring to light-duty
vehicles, they hold true for the HD market as well. Climate Nexus also indicates that
transitioning to electric vehicles will lead to a net increase in jobs, a claim that is partially
supported by the rising investment in batteries, vehicle manufacturing and charging stations.29
The expected investment mentioned by Climate Nexus is also supported by recent federal
investment through the IRA and BIL which will allow for increased investment along the vehicle
supply chain, including domestic battery manufacturing, charging infrastructure, and vehicle
manufacturing, both in the LD and HD markets.30 The IRA is expected to impact domestic
employment through conditions on eligibility for purchase incentives and battery manufacturing
incentives. These conditions include contingencies for domestic assembly, domestic critical
materials production, and domestic battery manufacturing. The BlueGreen Alliance and the
Political Economy Research Institute estimate that the IRA will create over 9 million jobs over
the next decade, with about 400,000 of those jobs being attributed directly to the IRA's battery
and fuel cell vehicle provisions.31 In addition, the IRA is expected to lead to increased demand in
ZEVs through tax credits for purchasers of ZEVs.

6.4.3 The Factor-Shift Effect

The factor-shift effect refers to employment changes due to changes in labor intensity of
production resulting from compliance activities. The proposed standards do not mandate the use
of a specific technology, and EPA anticipates that a compliant fleet under the proposed standards
would include a diverse range of technologies including ICE and ZEV technologies. In our
assessment that supports the appropriateness and feasibility of the proposed standards, we
developed a technology pathway that could be used to meet each of the standards, which project
increased ZEV adoption rates. A factor shift effect of this rule might occur if this proposed
regulation affects the labor intensity of production of ICE vehicles. It may also occur if a ZEV
replaces an ICE vehicle (holding total sales constant). We do not have data on how the regulation
might affect labor intensity of production within ICE vehicle production. ZEVs and ICE vehicles
require different inputs and have different costs of production, though there are some common

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parts as well. There is little research on the relative labor intensity needs of producing a HD ICE
vehicle and producing an equivalent HD ZEV. News articles and research from the light-duty
market do not provide a clear indication either. Some studies find that LD BEVs are less
complex than a comparable ICE vehicle, requiring fewer person-hours to assemble.32 Others find
that there is not a significant difference in the employment needed to produce LD ICE vehicles
when compared to BEVs. We do not have data on employment differences in traditional
manufacturing sectors and battery electric manufacturing sectors, especially for expected effects
in the future. As production in the related sectors of battery production and the construction of
charging and refueling stations is ramped up, their labor intensities may increase or decrease
relative to the No Action scenario. EPA does not have data on the employment needed to meet
future HD ZEV demand.

6.4.4 The Demand Effect

The demand effect refers to employment changes due to changes in new HD vehicle sales. In
general, if HD ICE vehicle sales increase, keeping the share of ZEVs in the new HD vehicle fleet
constant, more people would be needed to assemble trucks and the components used to
manufacturer them. On the other hand, if HD ZEV sales increase, we expect more people would
be needed to assemble ZEVs and their components, including batteries. If ZEVs and ICE
vehicles have different labor intensities of production, the relative change in ZEV and ICE sales
would impact the demand effect on employment. If, for example, the ZEV sales increased
relative to ICE vehicles, the increase in employment would depend on the relative labor
intensities. Additionally, short-term effects might be seen if pre- or low-buy were to occur,
depending on the magnitude of those effects (as discussed above). If they are of small
magnitudes, as expected, turnover of workers might not be affected. At higher magnitudes, if
pre-buy occurs, HD vehicle sales may increase temporarily, leading to temporary increases in
employment in the related manufacturing sectors. If low-buy occurs, there may be temporary
decreases in employment in the related manufacturing sectors.

6.4.5 The Cost Effect

The cost effect on employment refers to the impact on labor due to increased costs of
adopting technologies needed for vehicles to meet new emission standards, with the condition
that other factors (output and factor intensities) are held constant. In the HD ICE vehicle
manufacturing sector, if firms invest in lower-emitting HD ICE vehicles, there might be labor
used to implement those technologies. We do not expect the rule to require compliance activities
in the production of a ZEV, as such vehicles by definition emit zero emissions. In addition,
though the proposed standards do not mandate the use of a specific technology and EPA
anticipates that a compliant fleet under the proposed standards would include a diverse range of
technologies including ICE and ZEV technologies, in our assessment supporting the
appropriateness and feasibility of the proposed standards, we developed a technology pathway
which projects increased ZEV adoption rates that could be used to meet each of the standards.
Therefore, we expect little cost effect on employment due to this rule.

6.4.6 Overall Effects

In conclusion, the overall effect of the proposed rule on HD manufacturing employment
depends on the relative magnitude of factor-shift, cost, and demand effects. Due to a lack of data,
we are not able to estimate quantitative employment effects from this proposed rule on HD

427

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manufacturing. The qualitative discussion above suggests that the direction of impacts could be
positive or negative. Looking more broadly and including consideration of employment impacts
on battery manufacturing and battery and refueling infrastructure, Climate Nexus indicates that
transitioning to electric vehicles will lead to a net increase in jobs, as described in 6.4.2. This is
also supported by recent federal investment which will allow for increased investment along the
vehicle supply chain, including domestic battery manufacturing, charging infrastructure, and
vehicle manufacturing. The BIL was signed in November 2021 and provides over $24 billion in
investment in electric vehicle chargers, critical minerals, and components needed by domestic
manufacturers of EV batteries and for clean transit and school buses.xxv The CHIPS Act, signed
in August, 2022, invests in expanding America's manufacturing capacity for the semiconductors
used in electric vehicles and chargers. XXV1 The IRA provides incentives for producers to expand
domestic manufacturing of BEVs and domestic sourcing of components and critical minerals
needed to produce them.33 The IRA also provides incentives for consumers to purchase both new
and used ZEVs. These pieces of legislation are expected to create domestic employment
opportunities along the full automotive sector supply chain, from components and equipment
manufacturing and processing to final assembly, as well as incentivize the development of
reliable EV battery supply chains.xxvu Importantly, domestic employment is expected to be
positively impacted due to the domestic assembly, production and manufacturing conditions on
eligibility for purchase incentives and battery manufacturing incentives in the IRA. Estimates
from the BlueGreen Alliance and the Political Economy Research Institute state that the IRA
could lead to over 9 million jobs over the next decade, about 400,000 of which are attributed
directly to the IRA's battery and fuel cell vehicle provisions.34

6.4.7 Employment in Additional Related Sectors

As the share of ZEVs in the HD market increases, there may also be effects on employment in
the associated BEV charging and hydrogen refueling infrastructure industries, described in DRIA
Chapters 1.6 and 1.8. This can happen through many avenues, including greater demand for
charging and fueling infrastructure to support more ZEVs, leading to more private and public
charging facilities being constructed, or through greater use of existing facilities, which can lead
to increased maintenance needs for those facilities.

EPA expects possible employment impacts on additional downstream and upstream sectors
from the HD vehicle manufacturing. With respect to the potential for downstream effects, this
proposed action could provide some positive impacts on the supply of drivers in the heavy-duty
trucking industry. As discussed in Preamble Section IV, the reduction in fuel costs from
purchasing a ZEV instead of an ICE vehicle would be expected to not only reduce operating
costs for ZEV owners and operators, compared to an ICE vehicle, but may also provide

xxv The Bipartisan Infrastructure Law is officially titled the Infrastructure Investment and Jobs Act. More

information can be found at https://www.fhwa.dot.gov/bipartisan-infrastructure-law/

xxvl The CHIPS and Science Act was signed by President Biden in August, 2022 to boost investment in, and

manufacturing of, semiconductors in the U.S. The fact sheet can be found at https://www.whitehouse.gov/briefing-

room/statements-releases/2022/08/09/fact-sheet-chips-and-science-act-will-lower-costs-create-jobs-strengthen-

supply -chains- and-counter-china/

xxvn More information on how these Acts are expected to aid employment growth and create opportunities for growth
along the supply chain can be found in the January 2023 White House publication "Building a Clean Energy
Economy: A Guidebook to the Inflation Reduction Act's Investments in Clean Energy and Climate Action." found
online at https://www.whitehouse.gov/wp-content/uploads/2022/12/Inflation-Reduction-Act-Guidebook.pdf

428

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additional incentives to purchase a HD ZEV over a HD ICE vehicle. For example, in comments
submitted as part of the recent HD 2027 proposal, the Zero Emission Transportation Association
stated that driver satisfaction due to "a smoother ride with minimal vibrations, less noise
pollution, and a high-tech driving experience free from the fumes of diesel exhaust" has the
possibility of decreasing truck driver shortages and increasing driver retention.

Another potential downstream impact is on the services provided by HD vehicles. Because of
the diversity of the HD vehicle market, we expect entities from a wide range of transportation
sectors would purchase vehicles subject to the proposed emission standards. HD vehicles are
typically commercial in nature, and typically provide an "intermediate good," meaning that they
are used to provide a commercial service (transporting goods, municipal service vehicles, etc.),
rather than serving as final consumer goods themselves (as most light-duty vehicles do). As a
result, the purchase price of a new HD vehicle likely impacts the price of the service provided by
that vehicle. If lifetime operating cost savings, or purchase incentives (as might be available for a
new ZEV), are not accounted for in the prices for services provided by the new vehicles, this
may result in higher prices for the services provided by these vehicles compared to the same
services provided by a pre-regulation vehicle, and potentially reduce demand for the services
such vehicles provide. In turn, there may be less employment in the sectors providing such
services. We expect that the actual effects on demand for the services provided by these vehicles
and related employment would depend on cost pass-through, as well as responsiveness of
demand to increases in transportation cost, should such increases occur.xxvm

This action may also produce upstream employment effects in other sectors, for example, in
firms providing fuel. While reduced fuel consumption represents cost savings for purchasers of fuel,
it could also represent a loss in value of output for the petroleum refining industry, which could result
in reduced employment in that sector. Because the petroleum refining industry is material-intensive,
and EPA estimates the reduction in fuel consumption will be mainly met by reductions in oil imports
(see DRIA Chapter 6.5), the employment effect is not expected to be large.

6.5 Oil Imports and Electricity Consumption

The proposed CO2 emission standards would reduce not only GHG emissions but also liquid
fuel consumption while simultaneously increasing electricity consumption. Reducing fuel
consumption is a significant means of reducing GHG emissions from the transportation sector.
As discussed in Preamble Section V, we used an updated version of EPA's MOVES model to
estimate the impact of the proposed standards on heavy-duty vehicle emissions, fuel
consumption, and electricity consumption. Table 6-1 shows the estimated reduction in U.S. oil
imports under the proposed emission standards relative to the reference case scenario and also
shows the projected increase in electricity consumption due to the proposed rule. The oil import
reductions are the result of reduced consumption (i.e., reduced liquid fuel demand) of both diesel
fuel and gasoline and our estimate of 86.4 percent of reduced liquid fuel demand results in
reduced imports. The 86.4 percent oil import factor is calculated by taking the ratio of the
changes in U.S. net crude oil and refined petroleum product imports divided by the change in
U.S. oil consumption in two different AEO cases. To estimate the 86.4 percent import reduction
factor, we looked at changes in U.S. crude oil imports/exports and net refined petroleum
products in the AEO 2022 Reference Case, Table 11. Petroleum and Other Liquids Supply and

xxvm Cost pass-through refers to the amount of increase in up-front cost incurred by the HD vehicle owner that is
then passed on to their customers in the form of higher prices for services provided by the HD vehicle owner.

429

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Disposition, in comparison to the Low Economic Growth Case from the AEO 2022.35 Thus, on
balance, each gallon of petroleum reduced as a result of the proposed CO2 emission standards is
anticipated to reduce total U.S. imports of petroleum by 0.864 gallons.XX1X

To estimate how reductions in liquid fuel consumption translate to reductions in oil imports,
we used the following factors:

- Every gallon of reduced retail gasoline (E10) consumption consists of 10 percent ethanol
and 90 percent petroleum-based product (termed E0 for ease hereafter).

- Every gallon of reduced E0 has an energy density ratio of 0.881 relative to crude oil,
based on the ratio of energy densities of E0 (114,200 BTU/gallon) to crude oil (129,670
BTU/gallon).

- Every gallon of reduced diesel consumption has an energy density ratio of 0.998 relative
to crude oil, based on the ratio of energy densities of diesel fuel (129,488 BTU/gallon) to
crude oil (129,670 BTU/gallon).

42 gallons per barrel of crude oil.

Table 6-2 shows the impacts on fossil fuel consumption. The diesel and gasoline gallons are
straight gallons of retail liquid fuel, while the CNG reductions represent gasoline gallon
equivalents. We do not include CNG reductions in our estimates of oil import reductions or our
estimates of energy security benefits (see DRIA Chapter 7.3). We do include CNG reductions in
our estimate of monetized fuel savings (see DRIA Chapter 3.5.3) where we apply gasoline fuel
prices to the reduced gallons of gasoline equivalents.

Table 6-1 Estimated U.S. Oil Import Reductions and Electricity Consumption Increases due to the Proposal *

Calendar
Year

Imported

Oil
(Million
Barrels
per
Year)

%of
2021
U.S.
Imports

of
Crude

Electricity
Consumption
(GWh)

% of 2021

U.S.
Electricity
Consumption

Hydrogen
Consumption
(1000 metric tons
per year)

% of 2020
U.S. Hydrogen
Consumption

2027

-4.2

-0.2%

3,700

0.1%

0.0%

2028

-9

-0.4%

7,800

0.2%

0.0%

2029

-15

-0.7%

13,000

0.3%

0.0%

2030

-24

-1.1%

18,000

0.5%

130

1.3%

2031

-37

-1.7%

24,000

0.6%

440

4.4%

2032

-54

-2.4%

30,000

0.8%

830

8.3%

2033

-70

-3.1%

37,000

0.9%

1,200

12.3%

2034

-86

-3.9%

43,000

1.1%

1,600

16.2%

2035

-100

-4.5%

48,000

1.2%

2,000

20.2%

2036

-110

-5.1%

54,000

1.4%

2,400

24.0%

2037

-130

-5.7%

59,000

1.5%

2,800

27.6%

2038

-140

-6.3%

63,000

1.6%

3,100

31.0%

2039

-150

-6.8%

68,000

1.7%

3,400

34.2%

XX1X The estimated benefits from a reduction in U.S. oil imports are due to the U.S.'s decreased exposure to global
oil price shocks. We characterized these energy security benefits in Chapter 7.3 of this DRIA.

430

-------
2040

-160

-7.3%

72,000

1.8%

3,700

37.3%

2041

-170

-7.7%

75,000

1.9%

4,000

40.1%

2042

-180

-8.1%

79,000

2.0%

4,300

42.6%

2043

-190

-8.5%

82,000

2.1%

4,500

44.8%

2044

-200

00
00

©x

85,000

2.2%

4,700

46.8%

2045

-200

-9.1%

87,000

2.2%

4,800

48.4%

2046

-210

-9.3%

90,000

2.3%

5,000

49.8%

2047

-210

-9.5%

92,000

2.3%

5,100

50.9%

2048

-220

-9.7%

94,000

2.4%

5,200

51.7%

2049

-220

-9.9%

96,000

2.4%

5,300

52.7%

2050

-230

-10.1%

98,000

2.5%

5,400

53.7%

2051

-230

-10.3%

100,000

2.6%

5,500

54.6%

2052

-230

-10.5%

100,000

2.6%

5,500

55.3%

2053

-240

-10.7%

100,000

2.7%

5,600

56.1%

2054

-240

-10.8%

110,000

2.7%

5,700

56.7%

2055

-250

-11.0%

110,000

2.8%

5,700

57.3%

sum

-4,300

1,900,000

98,000

*According to EIA, 2021 US crude oil imports were 6.11 million barrels per day, or 2.23 billion barrels for the
year, 2021 U.S. electricity consumption was 3.93 trillion kWh, or 3.93 million GWh as of October 13, 2022, and
according to NREL in October 2020, U.S. hydrogen demand is 10 million metric tons annually.36 Note that the
electricity consumption presented here reflects changes in battery electric vehicle consumption and is the
consumption used in estimating fuel costs; it does not include changes in electricity generation to produce
hydrogen.

Table 6-2 Fossil Fuel Reductions due to the Proposal, Millions of gallons

Calendar Year

Diesel

Gasoline

CNG

(Gasoline Equivalents)

2027

-150

-75

-1.8

2028

-310

-160

-3.5

2029

-510

-270

-5.5

2030

-860

-390

-11

2031

-1,400

-520

-17

2032

-2,100

-700

-25

2033

-2,700

-870

-33

2034

-3,400

-1,000

-41

2035

-3,900

-1,200

-48

2036

-4,500

-1,400

-55

2037

-5,000

-1,500

-63

2038

-5,500

-1,700

-70

2039

-5,900

-1,800

-78

2040

-6,300

-2,000

-86

2041

-6,700

-2,100

-94

2042

-7,000

-2,300

-100

2043

-7,300

-2,400

-110

2044

-7,500

-2,500

-120

2045

-7,700

-2,700

-130

2046

-7,900

-2,800

-140

2047

-8,000

-2,900

-150

2048

-8,100

-3,000

-170

2049

-8,200

-3,100

-180

2050

-8,400

-3,300

-200

2051

-8,500

-3,400

-210

431

-------
2052

-8,600

-3,500

-230

2053

-8,700

-3,700

-250

2054

-8,800

-3,800

-270

2055

-8,800

-3,900

-290

sum

-160,000

-59,000

-3,200

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26 UAW. (2020). Taking the High Road: Strategies for a Fair EV Future. Retrieved from https://uaw.org/wp-
content/uploads/2019/07/190416-EV-White-Paper-REVISED-January-2020-Final.pdf

27 Herrmenn, F., Beinhauer, W., Borrmann, D., Hertwig, M., Mack, J., Potinecke, T., . . . Rally, P. (2020).
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32 Barrett, Jim and Josh Bivens. "The stakes for workers in how policymakers manage the coming shift to all-electric
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33 Inflation Reduction Act of 2022, H.R. 5376 (117th Cong., 2nd sess. 2022).

34 Political Economy Research Institute. (2022). Job Creation Estimates Through Proposed Inflation Reduction Act.
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35 See the spreadsheet, "AEO 2022 Change in product demand on imports.xlsx.

36 See "EIA_2021_petroleum_imports.pdf" and "EIA_2021_electricity_consumption.pdf" contained in the docket
for this rule, both last accessed on October 13, 2022. See "H2_consumption_NREL.pdf" contained in the docket for
this rule and last accessed on January 25, 2023.

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Chapter 7 Benefits

7.1 Climate Benefits

We estimate the social benefits of GHG reductions expected to occur as a result of the
proposed and alternative standards using estimates of the social cost of greenhouse gases (SC-
GHG)1, specifically using the social cost of carbon (SC-CO2), social cost of methane (SC-CH4),
and social cost of nitrous oxide (SC-N2O). The SC-GHG is the monetary value of the net harm to
society associated with a marginal increase in GHG emissions in a given year, or the benefit of
avoiding that increase. In principle, SC-GHG includes the value of all climate change impacts
(both negative and positive), including (but not limited to) changes in net agricultural
productivity, human health effects, property damage from increased flood risk and natural
disasters, disruption of energy systems, risk of conflict, environmental migration, and the value
of ecosystem services. The SC-GHG, therefore, reflects the societal value of reducing emissions
of the gas in question by one metric ton and is the theoretically appropriate value to use in
conducting benefit-cost analyses of policies that affect GHG emissions. In practice, data and
modeling limitations naturally restrain the ability of SC-GHG estimates to include all the
important physical, ecological, and economic impacts of climate change, such that the estimates
are a partial accounting of climate change impacts and will therefore tend to be underestimates of
the marginal benefits of abatement. The EPA and other Federal agencies began regularly
incorporating SC-GHG estimates in their benefit-cost analyses conducted under Executive Order
(E.O.) 12866" since 2008, following a Ninth Circuit Court of Appeals remand of a rule for
failing to monetize the benefits of reducing GHG emissions in that rulemaking process.

In 2017, the National Academies of Sciences, Engineering, and Medicine published a report
that provides a roadmap for how to update SC-GHG estimates used in Federal analyses going
forward to ensure that they reflect advances in the scientific literature (National Academies
2017). The National Academies' report recommended specific criteria for future SC-GHG
updates, a modeling framework to satisfy the specified criteria, and both near-term updates and
longer-term research needs pertaining to various components of the estimation process. The
research community has made considerable progress in developing new data and methods that
help to advance various components of the SC-GHG estimation process in response to the
National Academies' recommendations.

In a first-day executive order (E.O. 13990), Protecting Public Health and the Environment and
Restoring Science To Tackle the Climate Crisis, President Biden called for a renewed focus on
updating estimates of the social cost of greenhouse gases (SC-GHG) to reflect the latest science,

I Estimates of the social cost of greenhouse gases are gas-specific (e.g., social cost of carbon (SC-CO2), social cost
of methane (SC-CH4), social cost of nitrous oxide (SC-N2O)), but collectively they are referenced as the social cost
of greenhouse gases (SC-GHG).

II Presidents since the 1970s have issued executive orders requiring agencies to conduct analysis of the economic
consequences of regulations as part of the rulemaking development process. E.O. 12866, released in 1993 and still in
effect today, requires that for all regulatory actions that are significant under 3(f)(1), an agency provide an
assessment of the potential costs and benefits of the regulatory action, and that this assessment include a
quantification of benefits and costs to the extent feasible. For purposes of this action, monetized climate benefits are
presented for purposes of providing a complete benefit-cost analysis under E.O. 12866 and other relevant executive
orders. The estimates of change in GHG emissions and the monetized benefits associated with those changes play no
part in the record basis for this action.

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noting that "it is essential that agencies capture the full benefits of reducing greenhouse gas
emissions as accurately as possible." Important steps have been taken to begin to fulfill this
directive of E.O. 13990. In February 2021, the Interagency Working Group on the SC-GHG
(IWG) released a technical support document (hereinafter the "February 2021 TSD") that
provided a set of IWG recommended SC-GHG estimates while work on a more comprehensive
update is underway to reflect recent scientific advances relevant to SC-GHG estimation (IWG
2021). In addition, as discussed further below, EPA has developed a draft updated SC-GHG
methodology within a sensitivity analysis in the regulatory impact analysis of EPA's November
2022 supplemental proposal for oil and gas standards that is currently undergoing external peer
review and a public comment process.111

The EPA has applied the IWG's recommended interim SC-GHG estimates in the Agency's
regulatory benefit-cost analyses published since the release of the February 2021 TSD and is
likewise using them in this RIA. We have evaluated the SC-GHG estimates in the February 2021
TSD and have determined that these estimates are appropriate for use in estimating the social
benefits of GHG reductions expected to occur as a result of the proposed and alternative
standards. These SC-GHG estimates are interim values developed for use in benefit-cost
analyses until updated estimates of the impacts of climate change can be developed based on the
best available science and economics. After considering the TSD, and the issues and studies
discussed therein, EPA finds that these estimates, while likely an underestimate, are the best
currently available SC-GHG estimates until revised estimates have been developed reflecting the
latest, peer-reviewed science.

The SC-GHG estimates presented in the February 2021 SC-GHG TSD and used in this RIA
were developed over many years, using a transparent process, peer-reviewed methodologies, the
best science available at the time of that process, and with input from the public. Specifically, in
2009, an interagency working group (IWG) that included the EPA and other executive branch
agencies and offices was established to develop estimates relying on the best available science
for agencies to use. The IWG published SC-CO2 estimates in 2010 that were developed from an
ensemble of three widely cited integrated assessment models (IAMs) that estimate global climate
damages using highly aggregated representations of climate processes and the global economy
combined into a single modeling framework. The three IAMs were run using a common set of
input assumptions in each model for future population, economic, and CO2 emissions growth, as
well as equilibrium climate sensitivity (ECS)—a measure of the globally averaged temperature
response to increased atmospheric CO2 concentrations. These estimates were updated in 2013
based on new versions of each IAM.1V'V'V1 In August 2016 the IWG published estimates of the
social cost of methane (SC-CH4) and nitrous oxide (SC-N2O) using methodologies that are
consistent with the methodology underlying the SC-CO2 estimates. The modeling approach that
extends the IWG SC-CO2 methodology to non-CC>2 GHGs has undergone multiple stages of peer
review. The SC-CH4 and SC-N2O estimates were developed by Marten, Kopits, Griffiths,
Newbold, and Wolverton (2015) and underwent a standard double-blind peer review process
prior to journal publication. These estimates were applied in regulatory impact analyses of EPA

III See https://www.epa.gov/environmental-economics/scghg

IV Dynamic Integrated Climate and Economy (DICE) 2010 (Nordhaus 2010).

v Climate Framework for Uncertainty, Negotiation, and Distribution (FUND) 3.8 (Anthoff and Tol 2013a, 2013b)
V1 Policy Analysis of the Greenhouse Gas Effect (PAGE) 2009 (Hope 2013).

435

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proposed rulemakings with CH4 and N2O emissions impacts."1 The EPA also sought additional
external peer review of technical issues associated with its application to regulatory analysis.
Following the completion of the independent external peer review of the application of the
Marten et al. (2015) estimates, the EPA began using the estimates in the primary benefit-cost
analysis calculations and tables for a number of proposed rulemakings in 2015 (EPA 2015f,
2015g). The EPA considered and responded to public comments received for the proposed
rulemakings before using the estimates in final regulatory analyses in 2016.VU1 In 2015, as part of
the response to public comments received to a 2013 solicitation for comments on the SC-CO2
estimates, the IWG announced a National Academies of Sciences, Engineering, and Medicine
review of the SC-CO2 estimates to offer advice on how to approach future updates to ensure that
the estimates continue to reflect the best available science and methodologies. In January 2017,
the National Academies released their final report, Valuing Climate Damages: Updating
Estimation of the Social Cost of Carbon Dioxide, and recommended specific criteria for future
updates to the SC-GHG estimates, a modeling framework to satisfy the specified criteria, and
both near-term updates and longer-term research needs pertaining to various components of the
estimation process.1 Shortly thereafter, in March 2017, President Trump issued Executive Order
13783, which disbanded the IWG, withdrew the previous TSDs, and directed agencies to ensure
SC-GHG estimates used in regulatory analyses are consistent with the guidance contained in
OMB 's Circular A-4, "including with respect to the consideration of domestic versus
international impacts and the consideration of appropriate discount rates" (E.O. 13783, Section
5(c)). Benefit-cost analyses following E.O. 13783 used SC-GHG estimates that attempted to
focus on the specific share of climate change damages in the U.S. as captured by the models
(which did not reflect many pathways by which climate impacts affect the welfare of U.S.
citizens and residents) and were calculated using two discount rates recommended by Circular
A-4, 3 percent and 7 percent.lx All other methodological decisions and model versions used in
SC-GHG calculations remained the same as those used by the IWG in 2010 and 2013,
respectively.

On January 20, 2021, President Biden issued Executive Order 13990, which re-established an
IWG and directed it to develop an update of the social cost of carbon and other greenhouse gas
estimates that reflect the best available science and the recommendations of the National
Academies. In February 2021, the IWG recommended the interim use of the most recent SC-
GHG estimates developed by the IWG prior to the group being disbanded in 2017, adjusted for
inflation (IWG, 2021). As discussed in the February 2021 TSD, the IWG's selection of these
interim estimates reflected the immediate need to have SC-GHG estimates available for agencies
to use in regulatory benefit-cost analyses and other applications that were developed using a

vn The SC-CH4 and SC-N2O estimates were first used in sensitivity analysis for the Proposed Rulemaking for
Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles-
Phase 2 (U.S. EPA, 2015).

vm See IWG (2016b) for more discussion of the SC-CH4 and SC-N2O and the peer review and public comment
processes accompanying their development.

K The EPA regulatory analyses under E.O. 13783 included sensitivity analyses based on global SC-GHG values and
using a lower discount rate of 2.5%. OMB Circular A-4 (OMB, 2003) recognizes that special considerations arise
when applying discount rates if intergenerational effects are important. In the IWG's 2015 Response to Comments,
OMB—as a co-chair of the IWG—made clear that "Circular A-4 is a living document," that "the use of 7 percent is
not considered appropriate for intergenerational discounting," and that "[t]here is wide support for this view in the
academic literature, and it is recognized in Circular A-4 itself." OMB, as part of the IWG, similarly repeatedly
confirmed that "a focus on global SCC estimates in [regulatory impact analyses] is appropriate" (IWG 2015).

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transparent process, peer reviewed methodologies, and the science available at the time of that
process.

As noted above, EPA participated in the IWG but has also independently evaluated the
interim SC-GHG estimates published in the February 2021 TSD and determined they are
appropriate to use here to estimate climate benefits. The EPA and other agencies intend to
undertake a fuller update of the SC-GHG estimates that takes into consideration the advice of the
National Academies (2017) and other recent scientific literature. The EPA has also evaluated the
supporting rationale of the February 2021 TSD, including the studies and methodological issues
discussed therein, and concludes that it agrees with the rationale for these estimates presented in
the TSD and summarized below.

In particular, the IWG found that the SC-GHG estimates used under E.O. 13783 fail to reflect
the full impact of GHG emissions in multiple ways. First, the IWG concluded that those
estimates fail to capture many climate impacts that can affect the welfare of U.S. citizens and
residents. Examples of affected interests include direct effects on U.S. citizens and assets located
abroad, international trade, and tourism, and spillover pathways such as economic and political
destabilization and global migration that can lead to adverse impacts on U.S. national security,
public health, and humanitarian concerns. Those impacts are better captured within global
measures of the social cost of greenhouse gases.

In addition, assessing the benefits of U.S. GHG mitigation activities requires consideration of
how those actions may affect mitigation activities by other countries, as those international
mitigation actions will provide a benefit to U.S. citizens and residents by mitigating climate
impacts that affect U.S. citizens and residents. A wide range of scientific and economic experts
have emphasized the issue of reciprocity as support for considering global damages of GHG
emissions. Using a global estimate of damages in U.S. analyses of regulatory actions allows the
U.S. to continue to actively encourage other nations, including emerging major economies, to
take significant steps to reduce emissions. The only way to achieve an efficient allocation of
resources for emissions reduction on a global basis—and so benefit the U.S. and its citizens—is
for all countries to base their policies on global estimates of damages.

As a member of the IWG involved in the development of the February 2021 SC-GHG TSD,
the EPA agrees with this assessment and, therefore, in this RIA, the EPA centers attention on a
global measure of SC-GHG. This approach is the same as that taken in EPA regulatory analyses
over 2009 through 2016. A robust estimate of climate damages to U.S. citizens and residents that
accounts for the myriad of ways that global climate change reduces the net welfare of U.S.
populations does not currently exist in the literature. As explained in the February 2021 TSD,
existing estimates are both incomplete and an underestimate of total damages that accrue to the
citizens and residents of the U.S. because they do not fully capture the regional interactions and
spillovers discussed above, nor do they include all of the important physical, ecological, and
economic impacts of climate change recognized in the climate change literature, as discussed
further below. The EPA, as a member of the IWG, will continue to review developments in the
literature, including more robust methodologies for estimating the magnitude of the various
damages to U.S. populations from climate impacts and reciprocal international mitigation
activities, and explore ways to better inform the public of the full range of carbon impacts.

Second, the IWG concluded that the use of the social rate of return on capital (7 percent under
current OMB Circular A-4 guidance) to discount the future benefits of reducing GHG emissions

437

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inappropriately underestimates the impacts of climate change for the purposes of estimating the
SC-GHG. Consistent with the findings of the National Academies and the economic literature,
the IWG continued to conclude that the consumption rate of interest is the theoretically
appropriate discount rate in an intergenerational context, and recommended that discount rate
uncertainty and relevant aspects of intergenerational ethical considerations be accounted for in
selecting future discount rates.x'2'3'4'5 Furthermore, the damage estimates developed for use in the
SC-GHG are estimated in consumption-equivalent terms, and so an application of OMB Circular
A-4's guidance for regulatory analysis would then use the consumption discount rate to calculate
the SC-GHG. EPA agrees with this assessment and will continue to follow developments in the
literature pertaining to this issue. EPA also notes that while OMB Circular A-4, as published in
2003, recommends using 3% and 7% discount rates as "default" values, Circular A-4 also
reminds agencies that "different regulations may call for different emphases in the analysis,
depending on the nature and complexity of the regulatory issues and the sensitivity of the benefit
and cost estimates to the key assumptions." On discounting, Circular A-4 recognizes that
"special ethical considerations arise when comparing benefits and costs across generations," and
Circular A-4 acknowledges that analyses may appropriately "discount future costs and
consumption benefits.. .at a lower rate than for intragenerational analysis." In the 2015 Response
to Comments on the Social Cost of Carbon for Regulatory Impact Analysis, OMB, EPA, and the
other IWG members recognized that "Circular A-4 is a living document" and "the use of 7
percent is not considered appropriate for intergenerational discounting. There is wide support for
this view in the academic literature, and it is recognized in Circular A-4 itself." Thus, EPA
concludes that a 7% discount rate is not appropriate to apply to value the social cost of
greenhouse gases in the analysis presented in this proposal. In this analysis, to calculate the
present and annualized values of climate benefits, EPA uses the same discount rate as the rate
used to discount the value of damages from future GHG emissions, for internal consistency. That
approach to discounting follows the same approach that the February 2021 TSD recommends "to
ensure internal consistency—i.e., future damages from climate change using the SC-GHG at 2.5
percent should be discounted to the base year of the analysis using the same 2.5 percent rate."
EPA has also consulted the National Academies' 2017 recommendations on how SC-GHG
estimates can "be combined in RIAs with other cost and benefits estimates that may use different
discount rates." The National Academies reviewed "several options," including "presenting all
discount rate combinations of other costs and benefits with [SC-GHG] estimates."

While the IWG works to assess how best to incorporate the latest, peer reviewed science to
develop an updated set of SC-GHG estimates, it recommended the interim estimates to be the
most recent estimates developed by the IWG prior to the group being disbanded in 2017. The
estimates rely on the same models and harmonized inputs and are calculated using a range of
discount rates. As explained in the February 2021 TSD, the IWG has concluded that it is
appropriate for agencies to revert to the same set of four values drawn from the SC-GHG

x GHG emissions are stock pollutants, where damages are associated with what has accumulated in the atmosphere
over time, and they are long lived such that subsequent damages resulting from emissions today occur over many
decades or centuries depending on the specific greenhouse gas under consideration. In calculating the SC-GHG, the
stream of future damages to agriculture, human health, and other market and non-market sectors from an additional
unit of emissions are estimated in terms of reduced consumption (or consumption equivalents). Then that stream of
future damages is discounted to its present value in the year when the additional unit of emissions was released.
Given the long time horizon over which the damages are expected to occur, the discount rate has a large influence
on the present value of future damages.

438

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distributions based on three discount rates as were used in regulatory analyses between 2010 and
2016 and subject to public comment. For each discount rate, the IWG combined the distributions
across models and socioeconomic emissions scenarios (applying equal weight to each) and then
selected a set of four values for use in agency analyses: an average value resulting from the
model runs for each of three discount rates (2.5 percent, 3 percent, and 5 percent), plus a fourth
value, selected as the 95th percentile of estimates based on a 3 percent discount rate. The fourth
value was included to provide information on potentially higher-than-expected economic impacts
from climate change, conditional on the 3 percent estimate of the discount rate. As explained in
the February 2021 TSD, this update reflects the immediate need to have an operational SC-GHG
that was developed using a transparent process, peer-reviewed methodologies, and the science
available at the time of that process. Those estimates were subject to public comment in the
context of dozens of proposed rulemakings as well as in a dedicated public comment period in
2013.

Table 7-1, Table 7-2, and Table 7-3 summarize the interim SC-CO2, SC-CH4, and SC-N2O
estimates for the years 2023-2054.X1 These estimates are reported in 2020 dollars in the IWG's
2021 TSD but are otherwise identical to those presented in the IWG's 2016 TSD.6 For purposes
of capturing uncertainty around the SC-CO2 estimates in analyses, the February 2021 TSD
emphasizes the importance of considering all four of the SC-CO2 values. The SC-GHG increases
over time within the models (i.e., the societal harm from one metric ton emitted in 2030 is higher
than the harm caused by one metric ton emitted in 2025) because future emissions produce larger
incremental damages as physical and economic systems become more stressed in response to
greater climatic change, and because GDP is growing over time and many damage categories are
modeled as proportional to GDP.

X1 The February 2021 TSD provides SC-GHG estimates through emissions year 2050. Estimates were extended for
the period 2051 to 2054 using the IWG methods, assumptions, and parameters identical to the 2020-2050 estimates.
Specifically, 2051-2054 SC-GHG estimates were calculated in Mimi.jl, an open-source modular computing platform
used for creating, running, and performing analyses on IAMs (www.mimiframework.org). For CO2, the 2051-2054
SC-GHG values were calculated by linearly interpolating between the 2050 TSD values and the 2055 Mimi-based
values.

439

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Table 7-1 Interim Social Cost of Carbon Values, 2027-2055 (2021$/Metric Ton CO2)

Emissions Year

Discount Rate and Statistic

5% Average

3% Average

2.5% Average

3% 95th Percentile

2027

$19

$61

$89

$184

2028

$19

$62

$90

$187

2029

$20

$63

$92

$191

2030

$20

$64

$93

$194

2031

$21

$66

$95

$198

2032

$21

$67

$96

$202

2033

$22

$68

$97

$206

2034

$23

$69

$99

$210

2035

$23

$70

$100

$214

2036

$24

$71

$102

$218

2037

$24

$73

$103

$222

2038

$25

$74

$105

$226

2039

$26

$75

$106

$230

2040

$26

$76

$107

$234

2041

$27

$77

$109

$238

2042

$28

$79

$110

$242

2043

$28

$80

$112

$245

2044

$29

$81

$113

$249

2045

$30

$82

$114

$253

2046

$30

$83

$116

$256

2047

$31

$85

$117

$260

2048

$32

$86

$119

$263

2049

$32

$87

$120

$267

2050

$33

$88

$121

$271

2051

$34

$89

$123

$272

2052

$35

$90

$124

$273

2053

$35

$91

$125

$273

2054

$36

$92

$126

$274

2055

$36

$93

$128

$277

Note: The 2027-2055 SC-CO2 values are identical to those reported in the 2016 TSD (IWG 2016a) adjusted to
2021 dollars using the annual GDP Implicit Price Deflator values in the U. S. Bureau of Economic Analysis'
(BEA) NIPA Table 1.1.9 (U.S. BEA 2022). This table displays the values rounded to the nearest dollar; the annual
unrounded values used in the calculations in this analysis are available on OMB's website:
https://www.whitehouse.gOv/omb/information-regulatory-affairs/regulatory-matters/#scghgs.

The estimates were extended for the period 2051 to 2054 using methods, assumptions, and parameters identical to
the 2020-2050 estimates. The values are stated in $/metric ton CO2 and vary depending on the year of CO2
emissions.

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Table 7-2 Interim Social Cost of Carbon Values, 2027-2055 (2021$/Metric Ton CH4)

Emissions Year

Discount Rate and Statistic

5% Average

3% Average

2.5% Average

3% 95th Percentile

2027

$890

$1,900

$2,400

$5,000

2028

$920

$1,900

$2,500

$5,100

2029

$950

$2,000

$2,600

$5,300

2030

$980

$2,000

$2,600

$5,400

2031

$1,000

$2,100

$2,700

$5,600

2032

$1,000

$2,200

$2,700

$5,700

2033

$1,100

$2,200

$2,800

$5,900

2034

$1,100

$2,300

$2,900

$6,000

2035

$1,200

$2,300

$2,900

$6,200

2036

$1,200

$2,400

$3,000

$6,400

2037

$1,200

$2,400

$3,100

$6,500

2038

$1,300

$2,500

$3,100

$6,700

2039

$1,300

$2,600

$3,200

$6,800

2040

$1,300

$2,600

$3,300

$7,000

2041

$1,400

$2,700

$3,300

$7,200

2042

$1,400

$2,700

$3,400

$7,300

2043

$1,500

$2,800

$3,500

$7,500

2044

$1,500

$2,800

$3,500

$7,600

2045

$1,500

$2,900

$3,600

$7,800

2046

$1,600

$3,000

$3,700

$7,900

2047

$1,600

$3,000

$3,700

$8,100

2048

$1,600

$3,100

$3,800

$8,200

2049

$1,700

$3,100

$3,900

$8,400

2050

$1,700

$3,200

$3,900

$8,500

2051

$1,800

$3,200

$4,000

$8,600

2052

$1,800

$3,300

$4,000

$8,600

2053

$1,800

$3,300

$4,000

$8,600

2054

$1,800

$3,300

$4,100

$8,700

2055

$1,900

$3,400

$4,100

$8,700

Note: The 2027-2055 SC-CH4 values are identical to those reported in the 2016 TSD (IWG 2016a) adjusted to
2021 dollars using the annual GDP Implicit Price Deflator values in the U. S. Bureau of Economic Analysis'
(BEA) NIPA Table 1.1.9 (U.S. BEA 2022). This table displays the values rounded to the nearest dollar; the annual
unrounded values used in the calculations in this analysis are available on OMB's website:
https://www.whitehouse.gOv/omb/information-regulatory-affairs/regulatory-matters/#scghgs.

The estimates were extended for the period 2051 to 2054 using methods, assumptions, and parameters identical to
the 2020-2050 estimates. The values are stated in $/metric ton CH4 and vary depending on the year of CH4
emissions.

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Table 7-3 Interim Social Cost of Carbon Values, 2027-2055 (2021$/Metric Ton N2O)

Emissions Year

Discount Rate and Statistic

5% Average

3% Average

2.5% Average

3% 95th Percentile

2027

$7,500

$22,000

$32,000

$59,000

2028

$7,700

$23,000

$33,000

$60,000

2029

$7,900

$23,000

$33,000

$62,000

2030

$8,100

$24,000

$34,000

$63,000

2031

$8,400

$24,000

$35,000

$64,000

2032

$8,600

$25,000

$35,000

$66,000

2033

$8,900

$25,000

$36,000

$67,000

2034

$9,200

$26,000

$37,000

$69,000

2035

$9,400

$26,000

$37,000

$70,000

2036

$9,700

$27,000

$38,000

$71,000

2037

$9,900

$27,000

$39,000

$73,000

2038

$10,000

$28,000

$39,000

$74,000

2039

$10,000

$28,000

$40,000

$76,000

2040

$11,000

$29,000

$40,000

$77,000

2041

$11,000

$29,000

$41,000

$78,000

2042

$11,000

$30,000

$42,000

$80,000

2043

$12,000

$31,000

$42,000

$81,000

2044

$12,000

$31,000

$43,000

$83,000

2045

$12,000

$32,000

$44,000

$84,000

2046

$13,000

$32,000

$44,000

$86,000

2047

$13,000

$33,000

$45,000

$87,000

2048

$13,000

$33,000

$46,000

$89,000

2049

$13,000

$34,000

$46,000

$90,000

2050

$14,000

$34,000

$47,000

$92,000

2051

$14,000

$35,000

$48,000

$93,000

2052

$14,000

$35,000

$48,000

$94,000

2053

$15,000

$36,000

$49,000

$95,000

2054

$15,000

$37,000

$50,000

$97,000

2055

$15,000

$37,000

$50,000

$98,000

Note: The 2027-2055 SC-N2O values are identical to those reported in the 2016 TSD (IWG 2016a) adjusted to
2021 dollars using the annual GDP Implicit Price Deflator values in the U. S. Bureau of Economic Analysis'
(BEA) NIPA Table 1.1.9 (U.S. BEA 2022). This table displays the values rounded to the nearest dollar; the annual
unrounded values used in the calculations in this analysis are available on OMB's website:
https://www.whitehouse.gOv/omb/information-regulatory-affairs/regulatory-matters/#scghgs.

The estimates were extended for the period 2051 to 2054 using methods, assumptions, and parameters identical to
the 2020-2050 estimates. The values are stated in $/metric ton N2O and vary depending on the year of N2O
emissions.

There are a number of limitations and uncertainties associated with the SC-GHG estimates
presented in Table 7-1, Table 7-2, and Table 7-3. Some uncertainties are captured within the
analysis, while other areas of uncertainty have not yet been quantified in a way that can be
modeled. Figures 7.1-7.3 present the quantified sources of uncertainty in the form of frequency
distributions for the SC-CO2, SC-CH4, and SC-N2O estimates for emissions in 2030 (in 2021$).
The distribution of the SC-CO2 estimate reflects uncertainty in key model parameters such as the
equilibrium climate sensitivity, as well as uncertainty in other parameters set by the original

442

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model developers. To highlight the difference between the impact of the discount rate and other
quantified sources of uncertainty, the bars below the frequency distributions provide a symmetric
representation of quantified variability in the SC-CO2 estimates for each discount rate. As
illustrated by the figure, the assumed discount rate plays a critical role in the ultimate estimate of
the SC-CO2. This is because CO2 emissions today continue to impact society far out into the
future, so with a higher discount rate, costs that accrue to future generations are weighted less,
resulting in a lower estimate. As discussed in the February 2021 TSD, there are other sources of
uncertainty that have not yet been quantified and are thus not reflected in these estimates.

0 20 40 60 80 100 120 140 160 180 200 220 240 260 280 300 320 340

Social Cost of Carbon in 2030 [2021$ / metric ton C02]

Figure 7-1 Frequency Distribution of SC-CO2 Estimates for 2030xii

xu Although the distributions and numbers are based on the full Set of model results (150,000 estimates for each
discount rate and gas), for display purposes the horizontal axis is truncated with 0.47 to 0.89 percent of the estimates
falling below the lowest bin displayed and 0.30 to 3.7 percent of the estimates falling above the highest bin
displayed, depending on the discount rate and GHG.

443

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5% Average = $980

Discount Rate
D 5.0%

~ 3.0%

~ 2.5%

111 11 II
3500

III 111 111 11 111
4500 5500

5 - 95 Percentile
of Simulations

II 111 111 ill III ill III III III I
6500 7500 8500 9500

Social Cost of Methane in 2030 [2021$ / metric ton CH4]

Figure 7-2 Frequency Distribution of SC-CH4 Estimates for 2030x

5% Average = $8100

3% Average = $24000

Discount Rate

~ 5.0%

~ 3.0%

~ 2.5%

[2.5% Average = $34000

3%
95th Pet.

$63000

Vj, I I I

I 5 - 95 Percentile

ii in nun n in n mi ii in

0 8000 20000 32000

i ill ii ii ill in ii n ill ii iii r in

44000 56000 68000 80000

I III II
92000

of Simulations

ll< Tl III II II I IT II ill
104000 116000

Social Cost of Nitrous Oxide in 2030 [2021$ / metric ton N2OJ

Figure 7-3 Frequency Distribution of SC-N2O Estimates for 2030xiv

The interim SC-GHG estimates presented in Table 7-1, Table 7-2, and Table 7-3 have a
number of limitations. First, the current scientific and economic understanding of discounting
approaches suggests discount rates appropriate for intergenerational analysis in the context of
climate change are likely to be less than 3 percent, near 2 percent or lower.7 Second, the IA Ms
used to produce these interim estimates do not include all of the important physical, ecological,

Although the distributions and numbers are based on the full set of model results (150,000 estimates for each
discount rate and gas), for display purposes the horizontal axis is truncated with 0.018 to 0.106 percent of the
estimates falling below the lowest bin displayed and 0.42 to 2.88 percent of the estimates falling above the highest
bin displayed, depending on the discount rate and GHG.

m Although the distributions and numbers are based on the full set of model results (150,000 estimates for each
discount rate and gas), for display purposes the horizontal axis is truncated with 0.036 to 0.098 percent of the
estimates falling below the lowest bin displayed and 0.072 to 2.9 percent of the estimates falling above the highest
bin displayed, depending on the discount rate and GHG.

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and economic impacts of climate change recognized in the climate change literature and the
science underlying their "damage functions" - i.e., the core parts of the IAMs that map global
mean temperature changes and other physical impacts of climate change into economic (both
market and nonmarket) damages - lags behind the most recent research. For example, limitations
include the incomplete treatment of catastrophic and non-catastrophic impacts in the integrated
assessment models, their incomplete treatment of adaptation and technological change, the
incomplete way in which inter-regional and intersectoral linkages are modeled, uncertainty in the
extrapolation of damages to high temperatures, and inadequate representation of the relationship
between the discount rate and uncertainty in economic growth over long time horizons.

Likewise, the socioeconomic and emissions scenarios used as inputs to the models do not reflect
new information from the last decade of scenario generation or the full range of projections.

The modeling limitations do not all work in the same direction in terms of their influence on
the SC-GHG estimates. However, as discussed in the February 2021 TSD, the IWG has
recommended that, taken together, the limitations suggest that the SC-CO2 estimates used in this
rule likely underestimate the damages from GHG emissions. EPA concurs that the values used in
this RIA conservatively underestimate the rule's climate benefits. In particular, the
Intergovernmental Panel on Climate Change (IPCC) Fourth Assessment Report, which was the
most current IPCC assessment available at the time when the IWG decision over the ECS input
was made, concluded that SC-GHG estimates "very likely.. .underestimate the damage costs"
due to omitted impacts.8 Since then, the peer-reviewed literature has continued to support this
conclusion, as noted in the IPCC's Fifth Assessment report and other recent scientific
assessments.9'10'11'12'13'14'15'16 These assessments confirm and strengthen the science, updating
projections of future climate change and documenting and attributing ongoing changes. For
example, sea level rise projections from the IPCC's Fourth Assessment report ranged from 18 to
59 centimeters by the 2090s relative to 1980-1999, while excluding any dynamic changes in ice
sheets due to the limited understanding of those processes at the time. A decade later, the Fourth
National Climate Assessment projected a substantially larger sea level rise of 30 to 130
centimeters by the end of the century relative to 2000, while not ruling out even more extreme
outcomes. EPA has reviewed and considered the limitations of the models used to estimate the
interim SC-GHG estimates and concurs with the February 2021 SC-GHG TSD's assessment
that, taken together, the limitations suggest that the interim SC-GHG estimates likely
underestimate the damages from GHG emissions.

The February 2021 TSD briefly previews some of the recent advances in the scientific and
economic literature that the IWG is actively following and that could provide guidance on, or
methodologies for, addressing some of the limitations with the interim SC-GHG estimates. The
IWG is currently working on a comprehensive update of the SC-GHG estimates taking into
consideration recommendations from the National Academies of Sciences, Engineering and
Medicine, recent scientific literature, public comments received on the February 2021 TSD and
other input from experts and diverse stakeholder groups (National Academies 2017). While that
process continues, the EPA is continuously reviewing developments in the scientific literature on
the SC-GHG, including more robust methodologies for estimating damages from emissions, and
looking for opportunities to further improve SC-GHG estimation going forward. Most recently,
the EPA presented a draft set of updated SC-GHG estimates within a sensitivity analysis in the
regulatory impact analysis of the EPA's November 2022 supplemental proposal for oil and gas
standards that that aims to incorporate recent advances in the climate science and economics

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literature. Specifically, the draft updated methodology incorporates new literature and research
consistent with the National Academies near-term recommendations on socioeconomic and
emissions inputs, climate modeling components, discounting approaches, and treatment of
uncertainty, and an enhanced representation of how physical impacts of climate change translate
to economic damages in the modeling framework based on the best and readily adaptable
damage functions available in the peer reviewed literature. The EPA solicited public comment on
the sensitivity analysis and the accompanying draft technical report, which explains the
methodology underlying the new set of estimates, in the docket for the proposed Oil and Gas
rule. The EPA is also embarking on an external peer review of this technical report. More
information about this process and public comment opportunities is available on EPA's
website.xv EPA's draft technical report will be among the many technical inputs available to the
IWG as it continues its work.

7.1.1 Benefits of GHG Reductions

Tables Table 7-4 through Table 7-7 show the estimated monetary value of the estimated
changes in CO2, CH4, N2O, and total GHG emissions expected to occur over 2027 through 2055
for this proposal. The EPA estimated the dollar value of the GHG-related effects for each
analysis year between 2027 and 2055 by applying the SC-GHG estimates, shown in Table 7-1
through Table 7-3, to the estimated changes in GHG emissions in the corresponding year as
shown in Table 4-13. The EPA then calculated the present value (PV) and equivalent annualized
value (EAV) of benefits from the perspective of 2027 by discounting each year-specific value to
the year 2027 using the same discount rate used to calculate the SC-GHG.XV1

xv See https://www.epa.gov/environmental-economics/scghg

XV1 According to OMB's Circular A-4 (OMB 2003), an "analysis should focus on benefits and costs that accrue to
citizens and residents of the United States", and international effects should be reported, but separately. Circular A-4
also reminds analysts that "[different regulations may call for different emphases in the analysis, depending on the
nature and complexity of the regulatory issues." To correctly assess the total climate damages to U.S. citizens and
residents, an analysis should account for all the ways climate impacts affect the welfare of U.S. citizens and
residents, including how U.S. GHG mitigation activities affect mitigation activities by other countries, and spillover
effects from climate action elsewhere. The SC-GHG estimates used in regulatory analysis under revoked EO 13783
were a limited approximation of some of the U.S. specific climate damages from GHG emissions. These estimates
range from $8 per metric ton C02, $ 240 per metric ton CH4, and $2,759 per ton N20 (2021 dollars) using a 3
percent discount rate for emissions occurring in 2027 to $12 per metric ton C02, $397 per metric ton CH4, and
$4,459 per ton N20 using a 3 percent discount rate for emissions occurring in 2055. Applying the same estimate
(based on a 3% discount rate) to the GHG emissions reduction expected under this proposed rule would yield
benefits from climate impacts within U.S borders of $14 million in 2027, increasing to $1.4 billion in 2055 for C02,
$0.05 million in 2027, increasing to $13 million in 2055 for CH4, and $0.8 million in 2027, increasing to $69
million in 2055 for N20 . However, as discussed at length in the IWG's February 2021 SC-GHG TSD, these
estimates are an underestimate of the benefits of GHG mitigation accruing to U.S. citizens and residents, as well as
being subject to a considerable degree of uncertainty due to the manner in which they are derived. In particular, as
discussed in this analysis, EPA concurs with the assessment in the February 2021 SC-GHG TSD that the estimates
developed under revoked E.O. 13783 did not capture significant regional interactions, spillovers, and other effects
and so are incomplete underestimates. As the U.S. Government Accountability Office (GAO) concluded in a June
2020 report examining the SC-GHG estimates developed under E.O. 13783, the models "were not premised or
calibrated to provide estimates of the social cost of carbon based on domestic damages" p.29 (U.S. GAO 2020).
Further, the report noted that the National Academies found that country-specific social costs of carbon estimates
were "limited by existing methodologies, which focus primarily on global estimates and do not model all relevant
interactions among regions" p.26 (U.S. GAO 2020). It is also important to note that the SC-GHG estimates

446

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Table 7-4 Benefits of Reduced CO2 Emissions from the Proposal, Millions of 2021 dollars

Emissions Year

Discount Rate and Statistic

5% Average

3% Average

2.5% Average

3% 95th Percentile

2027

$31

$100

$150

$310

2028

$69

$220

$330

$680

2029

$120

$370

$540

$1,100

2030

$180

$570

$830

$1,700

2031

$270

$840

$1,200

$2,500

2032

$370

$1,200

$1,700

$3,500

2033

$490

$1,500

$2,200

$4,600

2034

$600

$1,800

$2,600

$5,600

2035

$710

$2,100

$3,100

$6,600

2036

$860

$2,600

$3,700

$7,900

2037

$1,000

$3,000

$4,300

$9,300

2038

$1,200

$3,500

$5,000

$11,000

2039

$1,400

$4,000

$5,700

$12,000

2040

$1,600

$4,500

$6,400

$14,000

2041

$1,800

$5,000

$7,100

$15,000

2042

$1,900

$5,500

$7,800

$17,000

2043

$2,100

$6,100

$8,500

$19,000

2044

$2,300

$6,600

$9,200

$20,000

2045

$2,500

$7,100

$9,800

$22,000

2046

$2,700

$7,500

$10,000

$23,000

2047

$2,900

$7,900

$11,000

$24,000

2048

$3,100

$8,300

$11,000

$25,000

2049

$3,200

$8,700

$12,000

$27,000

2050

$3,400

$9,100

$13,000

$28,000

2051

$3,600

$9,400

$13,000

$29,000

2052

$3,700

$9,700

$13,000

$29,000

2053

$3,900

$10,000

$14,000

$30,000

2054

$4,000

$10,000

$14,000

$31,000

2055

$4,100

$11,000

$15,000

$32,000

$20,000

$82,000

$130,000

$250,000

EAV

$1,300

$4,300

$6,100

$13,000

Note: Climate benefits include changes in vehicle CO2 emissions and EGU CO2 emissions, but do not include
changes refinery CO2 emissions.

developed under E.O. 13783 were never peer reviewed, and when their use in a specific regulatory action was
challenged, the U.S. District Court for the Northern District of California determined that use of those values had
been "soundly rejected by economists as improper and unsupported by science," and that the values themselves
omitted key damages to U.S. citizens and residents including to supply chains, U.S. assets and companies, and
geopolitical security. The Court found that by omitting such impacts, those estimates "fail[ed] to
consider... important aspect[s] of the problem" and departed from the "best science available" as reflected in the
global estimates. California v. Bernhardt, 472 F. Supp. 3d 573, 613-14 (N.D. Cal. 2020). The EPA continues to
center attention in this analysis on the global measures of the SC-GHG as the appropriate estimates given the flaws
in the U.S. specific estimates, and as necessary for all countries to use to achieve an efficient allocation of resources
for emissions reduction on a global basis, and so benefit the U.S. and its citizens.

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Table 7-5 Benefits of Reduced CH4 Emissions from the Proposal, Millions of 2021 dollars

Emissions Year

Discount Rate and Statistic

5% Average

3% Average

2.5% Average

3% 95th Percentile

2027

$0.15

$0.32

$0.41

$0.85

2028

$0.32

$0.68

$0.88

$1.8

2029

$0.53

$1.1

$1.4

$2.9

2030

$1.0

$2.0

$2.6

$5.3

2031

$1.5

$3.1

$4.0

$8.4

2032

$2.3

$4.7

$5.9

$12

2033

$3.2

$6.5

$8.3

$17

2034

$4.2

$8.4

$11

$22

2035

$5.2

$10

$13

$28

2036

$6.5

$13

$16

$35

2037

$7.9

$16

$20

$42

2038

$10

$19

$24

$51

2039

$11

$22

$28

$60

2040

$13

$26

$32

$69

2041

$15

$29

$36

$78

2042

$17

$33

$41

$87

2043

$19

$36

$45

$97

2044

$21

$40

$50

$110

2045

$23

$44

$55

$120

2046

$26

$49

$60

$130

2047

$28

$53

$66

$140

2048

$31

$58

$72

$160

2049

$34

$64

$78

$170

2050

$38

$70

$86

$190

2051

$41

$76

$94

$200

2052

$45

$83

$100

$220

2053

$49

$90

$110

$240

2054

$54

$98

$120

$250

2055

$58

$110

$130

$270

$200

$560

$770

$1,500

EAV

$13

$29

$38

$78

Note: Climate benefits include changes in vehicle CH4 emissions, but do not
include changes in EGU or refinery CH4 emissions.

Table 7-6 Benefits of Reduced N2O Emissions from the Proposal, Millions of 2021 dollars

Emissions Year

Discount Rate and Statistic

5% Average

3% Average

2.5% Average

3% 95th Percentile

2027

$1.9

$5.6

$8.2

$15

2028

$4.2

$12

$18

$33

2029

$7.1

$21

$30

$55

2030

$12

$35

$51

$93

2031

$20

$58

$84

$150

2032

$31

$88

$130

$230

2033

$41

$120

$170

$310

2034

$52

$150

$210

$390

2035

$63

$180

$250

$470

2036

$74

$210

$290

$550

448

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2037

$85

$230

$330

$620

2038

$95

$260

$370

$690

2039

$110

$290

$400

$760

2040

$120

$310

$440

$830

2041

$130

$340

$470

$900

2042

$140

$360

$500

$960

2043

$140

$380

$530

$1,000

2044

$150

$400

$560

$1,100

2045

$160

$420

$580

$1,100

2046

$170

$440

$600

$1,200

2047

$180

$450

$620

$1,200

2048

$180

$470

$640

$1,200

2049

$190

$480

$660

$1,300

2050

$200

$500

$680

$1,300

2051

$210

$510

$700

$1,400

2052

$210

$530

$720

$1,400

2053

$220

$540

$740

$1,400

2054

$230

$560

$760

$1,500

2055

$240

$570

$780

$1,500

$1,400

$5,000

$7,600

$13,000

EAV

$89

$260

$370

$700

Note: Climate benefits include changes in vehicle N20 emissions, but do not include changes in EGU or refinery
N2O emissions.

Table 7-7 Benefits of Reduced GHG Emissions from the Proposal, Millions of 2021 dollars

Emissions Year

Discount Rate and Statistic

5% Average

3% Average

2.5% Average

3% 95th Percentile

2027

$33

$110

$160

$320

2028

$74

$240

$350

$710

2029

$120

$400

$580

$1,200

2030

$190

$610

$880

$1,800

2031

$290

$900

$1,300

$2,700

2032

$410

$1,300

$1,800

$3,800

2033

$530

$1,600

$2,300

$4,900

2034

$660

$2,000

$2,800

$6,000

2035

$780

$2,300

$3,300

$7,100

2036

$940

$2,800

$4,000

$8,500

2037

$1,100

$3,300

$4,700

$9,900

2038

$1,300

$3,800

$5,400

$12,000

2039

$1,500

$4,300

$6,100

$13,000

2040

$1,700

$4,900

$6,900

$15,000

2041

$1,900

$5,400

$7,600

$16,000

2042

$2,100

$5,900

$8,300

$18,000

2043

$2,300

$6,500

$9,000

$20,000

2044

$2,500

$7,000

$9,800

$21,000

2045

$2,700

$7,500

$10,000

$23,000

2046

$2,900

$8,000

$11,000

$24,000

449

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2047

$3,100

$8,400

$12,000

$26,000

2048

$3,300

$8,800

$12,000

$27,000

2049

$3,500

$9,200

$13,000

$28,000

2050

$3,700

$9,700

$13,000

$30,000

2051

$3,800

$10,000

$14,000

$30,000

2052

$4,000

$10,000

$14,000

$31,000

2053

$4,100

$11,000

$15,000

$32,000

2054

$4,300

$11,000

$15,000

$32,000

2055

$4,400

$11,000

$15,000

$33,000

$22,000

$87,000

$130,000

$260,000

EAV

$1,400

$4,600

$6,500

$14,000

Note: Climate benefits include changes in vehicle GHGs and EGU C02 emissions, but do not include changes in
other EGU GHGs or refinery GHGs.

7.2 Estimated Human Health Benefits of Non-GHG Emission Reductions

This section discusses the economic benefits from reductions in health and environmental
impacts resulting from criteria pollutant emission reductions that can be expected to occur as a
result of the proposed and alternative standards. GHG emissions are predominantly the
byproduct of fossil fuel combustion processes that also produce criteria and hazardous air
pollutant emissions. The heavy-duty vehicles and engines that are subject to the proposed
standards are also significant sources of mobile source air pollution such as directly-emitted PM,
NOx, VOCs and air toxics. We expect the proposed and alternative CO2 emission standards
would lead to an increase in HD ZEVs, which would result in reductions of these non-GHG
pollutants (see Chapter 4). Zero-emission technologies would also affect emissions from
upstream sources that occur during, for example, electricity generation and from the refining and
distribution of fuel (see Chapter 4).xvu

Changes in ambient concentrations of ozone, PM2.5, and air toxics that will result from the
proposed standards are expected to affect human health by reducing premature deaths and other
serious human health effects, as well as other important improvements in public health and
welfare. Children especially benefit from reduced exposures to criteria and toxic pollutants
because they tend to be more sensitive to the effects of these respiratory pollutants. Ozone and
particulate matter have been associated with increased incidence of asthma and other respiratory
effects in children, and particulate matter has been associated with a decrease in lung maturation.

When feasible, EPA conducts full-scale photochemical air quality modeling to demonstrate
how its national mobile source regulatory actions affect ambient concentrations of regional
pollutants throughout the United States. The estimation of the human health impacts of a
regulatory action requires national-scale photochemical air quality modeling to conduct a full-

xvu This proposal's benefits analysis includes added emissions due to increased electricity generation but does not
include emissions reductions from reduced petroleum refining.

450

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scale assessment of PM2.5 and ozone-related health benefits. Air quality modeling and associated
analyses are not available for this notice.

For the analysis of the proposed and alternative CO2 emission standards, we instead use a
reduced-form "benefit-per-ton" (BPT) approach to estimate the monetized PIVh.s-related health
benefits of this proposal. The BPT approach estimates the monetized economic value of PM2.5-
related emission reductions (such as direct PM, NOx and SO2) due to implementation of the
proposed program. Similar to the SC-GHG approach for monetizing reductions in GHGs, the
BPT approach estimates monetized health benefits of avoiding one ton of PIVh.s-related
emissions from a particular onroad mobile or upstream source. The value of health benefits from
reductions (or increases) in PM2.5 emissions associated with this proposal were estimated by
multiplying PIVh.s-related BPT values by the corresponding annual reduction (or increase) in tons
of directly-emitted PM2.5 and PM2.5 precursor emissions (NOx and SO2).

The BPT approach monetizes avoided premature deaths and illnesses that are expected to
occur as a result of reductions in directly-emitted PM2.5 and PM2.5 precursors. A chief limitation
to using PM2.5-related BPT values is that they do not reflect benefits associated with reducing
ambient concentrations of ozone, direct exposure to NO2, or exposure to mobile source air
toxics, nor do they account for improved ecosystem effects or visibility. The estimated benefits
of this proposal would be larger if we were able to monetize these unquantified benefits at this
time.

Using the BPT approach, we estimate the present value of PIVh.s-related benefits of the
proposed program to be $15 to $29 billion at a 3% discount rate and $5.8 to $11 billion at a 7%
discount rate. Benefits are reported in year 2021 dollars and reflect the PIVh.s-related benefits
associated with reductions in NOx, SO2, and direct PM2.5 emissions. Because premature
mortality typically constitutes the vast majority of monetized benefits in a PM2.5 benefits
assessment, we present a range of PM benefits based on risk estimates reported from two
different long-term exposure studies using different cohorts to account for uncertainty in the
benefits associated with avoiding PM-related premature deaths (see Chapter 7.2.2).

7.2.1 Approach to Estimating Human Health Benefits

This section summarizes EPA's approach to estimating the economic value of the PM2.5-
related benefits for this proposal. We use a BPT approach that is conceptually consistent with
EPA's use of BPT estimates in its regulatory analyses.17'18 In this approach, the PIVh.s-related
BPT values are the total monetized human health benefits (the sum of the economic value of the
reduced risk of premature death and illness) that are expected from reducing one ton of NOx,
SO2 or directly-emitted PM2.5.

The mobile sector BPT estimates used in this proposal were published in 2019, but were
recently updated using the suite of premature mortality and morbidity studies in use by EPA for
the 2022 PM NAAQS Reconsideration Proposal.19'20 The upstream EGU BPT estimates used in
this proposal were also recently updated.21 The health benefits Technical Support Document
(Benefits TSD) that accompanied the 2023 PM NAAQS Proposal details the approach used to
estimate the PM2.5-related benefits reflected in these BPTs.22 We multiply these BPT values by
national reductions in annual emissions in tons to estimate the total monetized human health
benefits associated with the proposal.

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Our procedure for calculating BPT values follows three steps:

1. Using source apportionment photochemical modeling, predict annual average ambient
concentrations of NOx, SO2 and primary PM2.5 that are attributable to each source sector
(Onroad Heavy-Duty Diesel, Onroad Heavy-Duty Gas, and EGU), for the Continental U.S. (48
states). This yields the estimated ambient pollutant concentrations to which the U.S. population
is exposed.

2. For each sector, estimate the health impacts, and economic value of those impacts,
associated with the attributable ambient concentrations of NOx, SO2 and primary PM2.5 using the
environmental Benefits Mapping and Analysis Program-Community Edition (BenMAP-CE). xvm
This yields the estimated total monetized value of health effects associated with exposure to the
relevant pollutants by sector.

3. For each sector, divide the monetary value of health impacts by the inventory of associated
precursor emissions. That is, primary PM2.5 benefits for a given sector are divided by direct
PM2.5 emissions from that same sector, sulfate benefits are divided by SO2 emissions, and nitrate
benefits are divided by NOx emissions. This yields the estimated monetary value of one ton of
sector-specific direct PM2.5 SO2 or NOx emissions.

The quantified and monetized PM2.5 health categories that are included in the BPT values are
summarized in Table 7-8. Table 7-20 in Section 7.2.6 lists the PM2.5, ozone, and air toxics health
categories that are not quantified and monetized by the BPT approach and are therefore not
included in the estimated benefits analysis for this proposal.

xvm BenMAP-CE is an open-source computer program developed by the EPA that calculates the number and
economic value of air pollution-related deaths and illnesses. The software incorporates a database that includes
many of the concentration-response relationships, population files, and health and economic data needed to quantify
these impacts. Information on BenMAP is found at: https://www.epa.gov/benmap/benmap-community-edition, and
the source code is available at: https://github.com/BenMAPCE/BenMAP-CE.

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Table 7-8 Human Health Effects of PM2.5

Pollutant

Effect (age)

Effect
Quantified

Effect
Monetized

More
Information

Adult premature mortality based on cohort study
estimates (>17 or >64]

PM ISA

Infant mortality (<1]

PM ISA

Non-fatal heart attacks (>18]

PM ISA

Hospital admissions - cardiovascular (all]

¦/

PM ISA

Hospital admissions - respiratory (<19 and >64]

¦/

PM ISA

Hospital admissions - Alzheimer's disease (>64]

¦/

PM ISA

Hospital admissions - Parkinson's disease (>64]

¦/

PM ISA

Emergency department visits - cardiovascular (all]

PM ISA

Emergency department visits - respiratory (all]

PM ISA

Emergency hospital admissions (>65]

PM ISA

PM2.5

Non-fatal lung cancer (>29]

¦/

PM ISA

Stroke incidence (50-79]

¦/

PM ISA

New onset asthma (<12]

¦/

PM ISA

Exacerbated asthma - albuterol inhaler use (asthmatics, 6-
13]

¦/

PM ISA

Lost work days (18-64]

PM ISA

Other cardiovascular effects (e.g., doctor's visits,
prescription medication]

—

PM ISA1

Other respiratory effects (e.g., pulmonary function, other
ages]

—

PM ISA1

Other cancer effects (e.g., mutagenicity, genotoxicity]

—

PM ISA1

Other nervous system effects (e.g., dementia]

—

PM ISA1

Metabolic effects (e.g., diabetes, metabolic syndrome]

—

PM ISA1

Reproductive and developmental effects (e.g., low birth
weight, pre-term births]

—

PM ISA1

1 We assess these benefits qualitatively due to epidemiological or economic

data limitations.

Of the PM-related health endpoints listed in Table 7-8, EPA estimates the incidence of air
pollution effects for only those classified as either "causal" or "likely-to-be-causal" in the 2019

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PM Integrated Science Assessment (ISA) and the 2022 PM ISA update. 23>24>X1X The full
complement of human health effects associated with PM remains unquantified because of current
limitations in methods or available data. Thus, our quantified PM-related benefits omit a number
of known or suspected health effects linked with PM, either because appropriate health impact
functions are not available or because outcomes are not easily interpretable (e.g., changes in
heart rate variability).

We anticipate the proposed program will also yield benefits from reduced exposure to
ambient concentrations of ozone. However, the complex, non-linear photochemical processes
that govern ozone formation prevent us from developing reduced-form ozone BPT values for
mobile sources. This BPT approach also omits health effects associated with ambient
concentrations of NO2 as well as criteria pollutant-related welfare effects such as improvements
in visibility, reductions in materials damage, ecological effects from reduced PM deposition,
ecological effects from reduced nitrogen emissions, and vegetation effects from reduced ozone
exposure. A list of these unquantified benefits can be found in Table 7-20.

We also do not provide estimated monetized benefits due to reductions in mobile source air
toxics. This is primarily because currently available tools and methods to assess air toxics risk
from mobile sources at the national scale are not adequate for extrapolation to incidence
estimation or benefits assessment.

7.2.2 Estimating PM2.5-attributable Adult Premature Death

Of the PM2.5-related health endpoints listed in Table 7-8, adult premature deaths typically
account for the majority of total monetized PM benefits and are thus the primary component of
the PM2.5-related BPT values. In this section, we provide more detail on PM mortality effect
coefficients and the concentration-response functions that underlie the BPT values.

A substantial body of published scientific literature documents the association between PM2.5
concentrations and the risk of premature death.25'26 This body of literature reflects thousands of
epidemiology, toxicology, and clinical studies. The PM ISA, completed as part of the review of
the recently proposed PM standards and reviewed by the Clean Air Scientific Advisory
Committee (CASAC),27 concluded that there is a causal relationship between mortality and both
long-term and short-term exposure to PM2.5 based on the full body of scientific evidence. The
size of the mortality effect estimates from epidemiologic studies, the serious nature of the effect
itself, and the high monetary value ascribed to prolonging life make mortality risk reduction the
most significant health endpoint quantified in this analysis. EPA selects Hazard Ratios from
cohort studies to estimate counts of PM-related premature death, following a systematic
approach detailed in the Benefits TSD that accompanied the PM NAAQS Reconsideration
Proposal.

For adult PM-related mortality, the BPT values are based on the risk estimates from two
alternative long-term exposure mortality studies: the National Health Interview Survey (NHIS)
cohort study (Pope III et al., 2019) and an extended analysis of the Medicare cohort (Wu et al.,

X1X The ISA synthesizes the toxicological, clinical and epidemiological evidence to determine whether each pollutant
is causally related to an array of adverse human health outcomes associated with either acute (i.e., hours- or days-
long) or chronic (i.e. years-long) exposure. For each outcome, the ISA reports this relationship to be causal, likely to
be causal, suggestive of a causal relationship, inadequate to infer a causal relationship, or not likely to be a causal
relationship.

454

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2020).28'29 In past analyses, EPA has used two alternate estimates of mortality: one from the
American Cancer Society cohort and one from the Medicare cohort (Turner et al., 2016 and Di et
al., 2017, respectively).30'31 We use a risk estimate from Pope III et al., 2019 study in place of the
risk estimate from the Turner et al., 2016 analysis, as it: (1) includes a longer follow-up period
that includes more recent (and lower) PM2.5 concentrations; (2) the NHIS cohort is more
representative of the U.S. population than is the ACS cohort with respect to the distribution of
individuals by race, ethnicity, income and education.

Based on the 2022 Supplement to the PM ISA,32 EPA substituted a risk estimate from Wu et
al., 2020 in place of a risk estimate from Di et al., 2017. These two epidemiologic studies share
many attributes, including the cohort and model used to characterize population exposure to
PM2.5. As compared to Di et al., 2017, Wu et al., 2020 includes a longer follow-up period and
reflects more recent PM2.5 concentrations.

The PM ISA also concluded that the scientific literature supports the use of a no-threshold
log-linear model to portray the PM-mortality concentration-response relationship while
recognizing potential uncertainty about the exact shape of the concentration-response
relationship. The 2019 PM ISA, which informed the 2023 PM NAAQS proposal, reviewed
available studies that examined the potential for a population-level threshold to exist in the
concentration-response relationship. Based on such studies, the ISA concluded that "evidence
from recent studies reduce uncertainties related to potential co-pollutant confounding and
continues to provide strong support for a linear, no-threshold concentration-response
relationship."33 Consistent with this evidence, the Agency historically has estimated health
impacts above and below the prevailing NAAQS.

7.2.3 Economic Value of Health Benefits

The BPT values used in this analysis are a reduced-form approach for relating emission
reductions to reductions in ambient concentrations of PM2.5 and associated improvements in
human health. Reductions in ambient concentrations of air pollution generally decrease the risk
of future adverse health effects by a small amount for a large population. To monetize these
benefits, the appropriate economic measure is willingness to pay (WTP) for changes in risk of a
health effect. For some health effects, such as hospital admissions, WTP estimates are generally
not available, so we use the cost of treating or mitigating the effect. These cost-of-illness (COI)
estimates generally (although not necessarily in every case) understate the true value of
reductions in risk of a health effect. They tend to reflect the direct expenditures related to
treatment, but not the value of avoided pain and suffering from the health effect. The WTP and
COI unit values for each endpoint are provided in the Benefits TSD that accompanied the 2023
PM NAAQS Reconsideration Proposal. These unit values were used to monetize the underlying
health effects included in the PM2.5 BPT values.

Avoided premature deaths typically account for the majority of monetized PM2.5-related
benefits. The economics literature concerning the appropriate methodology for valuing
reductions in premature mortality risk is still developing and is the subject of continuing
discussion within the economics and public policy analysis community. Following the advice of
the SAB's Environmental Economics Advisory Committee (SAB-EEAC), EPA currently uses
the value of statistical life (VSL) approach in calculating estimates of mortality benefits. This
calculation provides the most reasonable single estimate of an individual's WTP for reductions

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in mortality risk.34 The VSL approach is a summary measure for the value of small changes in
mortality risk experienced by a large number of people.

EPA consulted several times with the SAB-EEAC on valuing mortality risk reductions and
continues work to update the Agency's guidance on the issue. Until updated guidance is
available, EPA determined that a single, peer-reviewed estimate applied consistently best reflects
the SAB-EEAC advice we have received. Therefore, EPA applies the VSL that was vetted and
endorsed by the SAB in the Agency's Guidelines for Preparing Economic Analyses.35 The mean
VSL across these studies is $4.8 million (1990$). We then adjust this VSL to account for the
currency year and to account for income growth from 1990 to the analysis year. Specifically, the
VSL applied in this analysis in 2021 dollars after adjusting for income growth is $9.9 million for
2021.

EPA is committed to using scientifically sound, appropriately reviewed evidence in valuing
changes in the risk of premature death and continues to engage with the SAB to identify
scientifically sound approaches to update its mortality risk valuation estimates. Most recently,
the Agency proposed new meta-analytic approaches for updating its estimates, which were
subsequently reviewed by the SAB-EEAC.36 EPA is taking the SAB's formal recommendations
under advisement.

7.2.4 Health Benefits Results

The value of health benefits from reductions in PM2.5 emissions associated with this proposal
were estimated by multiplying PIVh.s-related BPT values by the corresponding annual reduction
in tons of directly-emitted PM2.5 and PM2.5 precursor emissions (NOx and SO2). As explained in
above, the PM2.5 BPT values represent the monetized value of human health benefits, including
reductions in both premature mortality and nonfatal illnesses. Table 7-9 presents the PM2.5 BPT
values estimated from two different PM-related premature mortality cohort studies, Wu et al.,
2020 (the Medicare cohort study) and Pope III et al., 2019 (the NHIS cohort study). The table
reports different values by source and pollutant because different pollutant emissions do not
equally contribute to ambient PM2.5 formation and different emissions sources do not equally
contribute to population exposure and associated health impacts. BPT values are also estimated
using either a 3 percent or 7 percent discount rate to account for avoided health outcomes that are
expected to accrue over more than a single year (the "cessation lag" between the change in PM
exposures and the total realization of changes in health effects). The source sectors include:
onroad heavy-duty diesel trucks, onroad heavy-duty gasoline trucks, and electricity generating
units (EGUs). We note that reductions in emissions from refineries are not monetized in this
analysis; benefits would be larger if the avoided health incidence attributable to reductions in
those emissions were included in the benefits total.

Table 7-10 and Table 7-11 present the NOx, SO2 and direct PM2.5 emission reductions, and
associated monetized PM2.5-related health benefits, of the proposed program for heavy-duty
diesel and heavy-duty gasoline vehicles, respectively. Table 7-12 and Table 7-13 present similar
results for the alternative program. Benefits for each heavy-duty vehicle type (diesel or gasoline
engine) are presented for the stream of years beginning with the first year of rule
implementation, 2027, through 2055. The tables also include the present value (PV) and
equivalent annualized value (EAV) of the stream of benefits over this time series, discounted
using both 3-percent and 7-percent discount rates. Table 7-14 and Table 7-15 present the year-
over-year total onroad heavy-duty vehicle benefits (diesel plus gasoline) associated with the

456

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proposed and alternative standards, along with the present value and equivalent annualized value
of benefits. Table 7-16 and Table 7-17 present the NOx, SO2, and direct PM2.5 emissions
increases, and associated monetized PIVh.s-related health impacts, for EGUs for the proposal and
alternative. Table 7-18 and Table 7-19 present the total net PIVh.s-related benefits (onroad heavy-
duty vehicles minus EGUs) for the proposal and the alternative.

Table 7-9 PMj.s-related Benefit Per Ton values (2021$) associated with the reduction of NOx, SO2 and
directly emitted PM2.5 emissions for (A) Onroad Heavy-Duty Diesel Vehicles, (B) Onroad Heavy-Duty
Gasoline Vehicles, and (C) Electricity Generating Units.

A. Onroad Heavy-Duty Diesel

NOx

3% Discount 7% Discount

S02

Direct PM

Rate

3% Discount
Rate

7% Discount
Rate

3% Discount
Rate

7% Discount
Rate

Pope

2025

$6,250

$13,300

$5,610

$12,000

$265,000

$569,000

$237,000

$512,000

$414,000

$889,000

$372,000

$799,000

2030

$7,030

$14,500

$6,320

$13,000

$302,000

$627,000

$271,000

$564,000

$472,000

$979,000

$424,000

$880,000

2035

$7,900

$15,900

$7,100

$14,300

$345,000

$699,000

$310,000

$628,000

$539,000

$1,090,000

$484,000

$981,000

2040

$8,610

$17,100

$7,740

$15,300

$385,000

$767,000

$346,000

$690,000

$602,000

$1,200,000

$540,000

$1,080,000

2045

$9,120

$17,900

$8,200

$16,100

$421,000

$827,000

$378,000

$744,000

$656,000

$1,290,000

$589,000

$1,160,000

2050

$9,430

$18,300

$8,480

$16,500

$451,000

$876,000

$405,000

$788,000

$700,000

$1,360,000

$629,000

$1,220,000

2055

$9,810

$18,900

$8,810

$17,000

$484,000

$931,000

$435,000

$837,000

$748,000

$1,440,000

$672,000

$1,290,000

B. Onroad Heavy-Duty Gasoline

NOx SO2 Direct PM

7% Discount

3% Discount Rate Rate 3% Discount Rate 7% Discount Rate 3% Discount Rate 7% Discount Rate

Pope

2025

$6,160

$13,100

$5,530

$11,800

$142,000

$304,000

$128,000

$274,000

$543,000

$1,160,000

$487,000

$1,040,000

2030

$6,940

$14,300

$6,240

$12,800

$162,000

$335,000

$145,000

$301,000

$619,000

$1,280,000

$556,000

$1,150,000

2035

$7,820

$15,700

$7,020

$14,100

$184,000

$372,000

$166,000

$335,000

$708,000

$1,430,000

$636,000

$1,280,000

2040

$8,550

$16,900

$7,680

$15,200

$206,000

$408,000

$185,000

$367,000

$792,000

$1,570,000

$711,000

$1,410,000

2045

$9,100

$17,800

$8,170

$16,000

$224,000

$438,000

$201,000

$394,000

$863,000

$1,690,000

$775,000

$1,520,000

2050

$9,450

$18,300

$8,490

$16,500

$238,000

$463,000

$214,000

$416,000

$921,000

$1,790,000

$828,000

$1,610,000

2055

$9,860

$19,000

$8,860

$17,100

$255,000

$490,000

$229,000

$441,000

$981,000

$1,880,000

$882,000

$1,690,000

C. Electricity Generating Units (EGUs)

NOx SO2 Direct PM

7% Discount

3% Discount Rate Rate 3% Discount Rate 7% Discount Rate 3% Discount Rate 7% Discount Rate
Wu Pope Wu Pope Wu Pope Wu Pope Wu Pope Wu Pope

2025

$7,470

$15,800

$6,710

$14,200

$55,200

$118,000

$49,700

$106,000

$110,000

$235,000

$98,400

$211,000

2030

$8,370

$17,100

$7,530

$15,400

$62,300

$129,000

$56,000

$116,000

$125,000

$258,000

$112,000

$232,000

2035

$9,370

$18,700

$8,420

$16,900

$69,900

$141,000

$62,900

$127,000

$142,000

$287,000

$128,000

$258,000

2040

$10,200

$20,000

$9,130

$18,000

$76,400

$152,000

$68,700

$136,000

$158,000

$314,000

$142,000

$283,000

Notes: All estimates are rounded to three significant figures. The benefit-per-ton estimates presented in this table assume either
a 3 percent or 7 percent discount rate in the valuation of premature mortality to account for a twenty-year segmented cessation
lag. Benefit-per-ton values were estimated for the years 2025, 2030, 2035, 2040, 2045 and 2050. We interpolated values for
intervening years (e.g., the 2032 BPT values are linearly interpolated using BPT values for 2030 and 2035, 2048 BPT values
are linearly interpolated using 2045 and 2050 BPT values; and so on) and linearly extrapolated values out to 2055 based on the
previous 5-year trend.

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Table 7-10 Summary of the estimated tons of reduced NOx, SO2 and direct PM2.5 per year from Heavy-Duty
Diesel Vehicles and the associated monetized PIVh.s-related health benefits (millions, 2021$) for the proposed
program

NOx Reduction Benefits

S02 Reduction Benefits

Direct PM Reduction Benefits

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

2027

370

$2.4-5.1

$2.2-4.6

5.4

$1.5-3.2

$1.4-2.9

$11-23

$9.7-20

2028

790

$5.3-11

$4.8-10

$3.3-7

$3-6.3

$24-50

$21-45

2029

1,300

$8.9-18

$8-17

$5.6-12

$5-11

$39-82

$35-74

2030

2,200

$15-31

$14-28

$9.7-20

$8.7-18

140

$65-140

$59-120

2031

3,700

$27-54

$24-49

$16-34

$15-30

220

$110-220

$95-200

2032

5,500

$41-83

$37-75

$25-51

$22-46

310

$160-320

$140-290

2033

7,800

$59-120

$53-110

100

$33-68

$30-61

410

$210-430

$190-380

2034

10,000

$79-160

$71-140

130

$42-86

$38-77

500

$260-530

$240-480

2035

13,000

$100-210

$93-190

150

$51-100

$46-93

590

$320-640

$280-580

2036

17,000

$130-270

$120-240

170

$59-120

$53-110

670

$370-750

$330-670

2037

21,000

$170-350

$160-310

190

$68-140

$61-120

750

$420-850

$380-760

2038

26,000

$220-430

$190-390

210

$78-160

$70-140

820

$470-950

$430-850

2039

30,000

$260-510

$230-460

220

$84-170

$75-150

890

$520-1000

$470-940

2040

34,000

$300-590

$270-530

240

$91-180

$82-160

950

$570-1100

$510-1000

2041

38,000

$330-650

$300-590

250

$98-190

$88-170

1,000

$620-1200

$560-1100

2042

41,000

$360-720

$330-640

260

$100-210

$94-190

1,100

$660-1300

$590-1200

2043

44,000

$390-770

$350-690

270

$110-220

$99-200

1,100

$700-1400

$630-1200

2044

46,000

$420-820

$370-740

280

$120-230

$100-210

1,100

$730-1400

$660-1300

2045

48,000

$440-860

$400-780

290

$120-240

$110-210

1,200

$770-1500

$690-1400

2046

50,000

$460-900

$410-810

300

$130-250

$110-220

1,200

$800-1600

$720-1400

2047

51,000

$470-930

$430-830

300

$130-250

$120-230

1,200

$820-1600

$740-1400

2048

52,000

$490-950

$440-860

300

$130-260

$120-230

1,200

$840-1600

$760-1500

2049

54,000

$500-980

$450-880

310

$140-270

$120-240

1,300

$870-1700

$780-1500

2050

55,000

$520-1000

$460-900

310

$140-270

$130-250

1,300

$890-1700

$800-1600

2051

56,000

$530-1000

$480-930

320

$140-280

$130-250

1,300

$920-1800

$820-1600

2052

57,000

$540-1100

$490-950

320

$150-290

$130-260

1,300

$940-1800

$850-1600

2053

57,000

$560-1100

$500-970

320

$150-290

$140-260

1,300

$970-1900

$870-1700

2054

58,000

$570-1100

$510-980

330

$160-300

$140-270

1,300

$990-1900

$890-1700

2055

59,000

$580-1100

$520-1000

330

$160-310

$140-280

1,400

$1000-1900

$910-1800

Present
Value

$4,700-9,200

$2,100-4,100

$1,400-2,800

$660-1,300

$9,100-18,000

$4,100-8,200

EAV

$250-480

$170-330

$75-150

$54-110

$470-930

$340-670

Table 7-11 Summary of the estimated tons of reduced NOx, SO2 and direct PM2.5 per year from Heavy-Duty
Gasoline Vehicles and the associated monetized PIVh.s-related health benefits (millions, 2021$) for the
proposed program

NOx Reduction Benefits

S02 Reduction Benefits

Direct PM Reduction Benefits

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

2027

130

$0.81-1.7

$0.73-1.5

3.5

$0.49-1.0

$0.44-0.93

$6.6-14

$5.9-12

2028

300

$1.9-3.9

$1.7-3.5

7.5

$1.1-2.3

$0.98-2.1

$15-32

$14-29

2029

510

$3.3-6.8

$2.9-6.1

$1.8-3.8

$1.6-3.4

$26-54

$23-49

2030

770

$5.1-10

$4.6-9.4

$2.7-5.7

$2.5-5.1

$40-82

$36-74

2031

1,100

$7.6-16

$6.8-14

$3.8-7.9

$3.4-7.1

$58-120

$52-110

2032

1,600

$11-22

$9.9-20

$5.3-11

$4.7-9.7

140

$84-170

$76-150

2033

2,100

$15-30

$13-27

$6.8-14

$6.1-12

180

$110-230

$100-200

2034

2,600

$19-38

$17-34

$8.3-17

$7.5-15

220

$140-290

$130-260

2035

3,100

$23-46

$21-42

$9.9-20

$8.9-18

260

$170-350

$150-310

458

-------
2036

3,700

$28-55

$25-50

$11-23

$10-21

300

$210-410

$180-370

2037

4,200

$32-64

$29-58

$13-26

$12-24

340

$240-480

$220-430

2038

4,700

$37-73

$33-66

$15-30

$13-27

380

$280-550

$250-500

2039

5,200

$42-83

$37-74

$16-33

$15-30

430

$310-620

$280-560

2040

5,700

$47-92

$42-83

$18-36

$16-32

470

$350-690

$310-620

2041

6,200

$51-100

$46-90

100

$20-39

$18-35

500

$380-760

$350-680

2042

6,700

$55-110

$50-98

110

$22-43

$19-38

540

$420-830

$380-750

2043

7,100

$60-120

$54-110

110

$23-46

$21-41

580

$460-900

$410-810

2044

7,600

$64-130

$58-110

120

$25-49

$22-44

620

$490-970

$440-870

2045

8,000

$69-130

$62-120

130

$27-52

$24-47

650

$530-1,000

$480-940

2046

8,400

$73-140

$66-130

130

$28-55

$25-50

680

$570-1,100

$510-1,000

2047

8,800

$77-150

$69-140

140

$30-59

$27-53

720

$600-1,200

$540-1,100

2048

9,200

$81-160

$73-140

140

$32-62

$28-55

750

$640-1,200

$570-1,100

2049

9,700

$86-170

$77-150

150

$33-65

$30-58

780

$680-1,300

$610-1,200

2050

10,000

$90-170

$81-160

160

$35-68

$32-61

820

$710-1,400

$640-1,200

2051

10,000

$95-180

$85-160

160

$37-72

$33-65

850

$750-1,500

$680-1,300

2052

11,000

$99-190

$89-170

170

$39-76

$35-68

890

$790-1,500

$710-1,400

2053

11,000

$100-200

$93-180

180

$41-79

$37-71

920

$830-1,600

$750-1,400

2054

12,000

$110-210

$97-190

180

$43-83

$39-75

950

$880-1,700

$790-1,500

2055

12,000

$110-220

$100-200

190

$45-87

$41-79

990

$920-1,800

$820-1,600

Present
Value

$870-1,700

$380-760

$350-680

$160-310

$6,800-13,000

$3,000-5,900

EAV

$45-89

$31-62

$18-36

$13-25

$350-690

$240-480

Table 7-12 Summary of the estimated tons of reduced NOx, SO2 and direct PM2.5 per year from Heavy-Duty
Diesel Vehicles and the associated monetized PIVh.s-related health benefits (millions, 2021$) for the alternative
program

NOx Reduction Benefits

S02 Reduction Benefits

Direct PM Reduction Benefits

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

2027

190

$1.3-2.7

$1.1-2.4

2.8

$0.77-1.6

$0.70-1.5

$5.8-12

$5.2-11

2028

480

$3.2-6.7

$2.9-6.0

6.9

$2.0-4.2

$1.8-3.8

$14-30

$13-27

2029

820

$5.6-12

$5.0-10

$3.5-7.3

$3.2-6.6

$25-52

$23-47

2030

1,500

$11-22

$9.6-20

$6.7-14

$6.0-13

$46-95

$41-85

2031

2,600

$18-38

$17-34

$11-23

$10-21

150

$74-150

$67-140

2032

3,900

$29-58

$26-52

$17-36

$16-32

220

$110-230

$100-210

2033

5,400

$40-82

$36-74

$24-48

$21-43

290

$150-300

$130-270

2034

7,100

$55-110

$49-100

$30-61

$27-55

360

$190-380

$170-340

2035

9,100

$72-140

$65-130

100

$36-73

$32-66

420

$230-460

$200-410

2036

12,000

$96-190

$86-170

120

$42-85

$38-77

480

$260-530

$240-480

2037

15,000

$120-250

$110-220

130

$48-97

$43-87

530

$300-600

$270-540

2038

18,000

$150-310

$140-280

150

$54-110

$49-97

590

$340-680

$300-610

2039

22,000

$180-360

$160-330

160

$60-120

$54-110

630

$370-740

$340-670

2040

25,000

$210-420

$190-380

170

$65-130

$58-120

680

$410-810

$370-730

2041

27,000

$240-470

$210-420

180

$70-140

$63-120

720

$440-870

$400-780

2042

29,000

$260-510

$230-460

190

$75-150

$67-130

750

$470-930

$420-840

2043

31,000

$280-550

$250-500

190

$79-160

$71-140

790

$500-980

$450-880

2044

33,000

$300-590

$270-530

200

$83-160

$75-150

810

$520-1000

$470-930

2045

35,000

$320-620

$280-560

210

$87-170

$78-150

830

$550-1100

$490-970

2046

36,000

$330-640

$300-580

210

$90-180

$81-160

850

$570-1100

$510-1000

2047

37,000

$340-660

$310-600

210

$93-180

$83-160

870

$590-1100

$530-1000

2048

38,000

$350-680

$310-610

220

$95-190

$86-170

880

$600-1200

$540-1100

2049

38,000

$360-700

$320-630

220

$98-190

$88-170

890

$620-1200

$550-1100

2050

39,000

$370-720

$330-650

220

$100-200

$90-180

910

$640-1200

$570-1100

2051

40,000

$380-740

$340-670

230

$100-200

$93-180

920

$650-1300

$590-1100

2052

41,000

$390-760

$350-680

230

$110-210

$95-190

930

$670-1300

$600-1200

2053

41,000

$400-770

$360-690

230

$110-210

$98-190

940

$690-1300

$620-1200

459

-------
2054

42,000

$410-780

$370-710

230

$110-220

$100-190

950

$700-1400

$630-1200

2055

42,000

$410-800

$370-720

240

$110-220

$100-200

960

$720-1400

$650-1200

Present
Value

$3,400-
6,600

$1,500-2,900

$1,000-
2,000

$470-930

$6,500-13,000

$2,900-5,800

EAV

$180-340

$120-240

$53-110

$38-75

$340-660

$240-480

Table 7-13 Summary of the estimated tons of reduced NOx, SO2 and direct PM2.5 per year from Heavy-Duty
Gasoline Vehicles and the associated monetized PIVh.s-related health benefits (millions, 2021$) for the
alternative program

NOx Reduction Benefits

S02 Reduction Benefits

Direct PM Reduction Benefits

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

2027

$0.50-1.1

$0.45-0.95

1.9

$0.28-0.59

$0.25-0.53

6.9

$4.0-8.4

$3.6-7.5

2028

200

$1.3-2.8

$1.2-2.5

4.6

$0.71-1.5

$0.64-1.3

$10-22

$9.4-20

2029

370

$2.5-5.1

$2.2-4.6

8.1

$1.3-2.7

$1.2-2.4

$19-40

$17-36

2030

580

$4.1-8.3

$3.6-7.5

$2.0-4.2

$1.8-3.8

$31-64

$28-57

2031

870

$6.2-13

$5.6-11

$3.0-6.1

$2.7-5.5

$47-97

$42-87

2032

1,200

$9.0-18

$8.0-16

$4.1-8.5

$3.7-7.6

100

$68-140

$61-120

2033

1,600

$12-24

$11-22

$5.3-11

$4.8-9.8

130

$90-180

$80-160

2034

2,000

$15-30

$14-27

$6.5-13

$5.9-12

160

$110-230

$100-210

2035

2,400

$18-37

$17-33

$7.8-16

$7.0-14

190

$140-280

$120-250

2036

2,800

$22-44

$20-40

$9.0-18

$8.1-16

230

$160-330

$150-300

2037

3,200

$26-51

$23-46

$10-21

$9.2-18

260

$190-380

$170-340

2038

3,600

$29-58

$26-52

$12-23

$10-21

290

$220-440

$200-390

2039

3,900

$33-65

$30-59

$13-25

$12-23

320

$250-490

$220-440

2040

4,300

$37-72

$33-65

$14-28

$13-25

350

$270-540

$250-490

2041

4,600

$40-79

$36-71

$15-31

$14-27

370

$300-600

$270-540

2042

5,000

$43-85

$39-77

$17-33

$15-30

400

$330-650

$300-580

2043

5,300

$47-92

$42-83

$18-35

$16-32

430

$360-700

$320-630

2044

5,600

$50-98

$45-88

$19-38

$17-34

450

$390-760

$350-680

2045

5,900

$54-100

$48-94

$21-40

$19-36

480

$410-810

$370-730

2046

6,200

$57-110

$51-100

$22-43

$20-39

500

$440-860

$400-770

2047

6,500

$60-120

$54-110

100

$23-45

$21-41

530

$470-910

$420-820

2048

6,800

$63-120

$57-110

100

$24-47

$22-43

550

$500-970

$450-870

2049

7,100

$66-130

$60-120

110

$26-50

$23-45

580

$520-1,000

$470-920

2050

7,400

$70-140

$63-120

110

$27-53

$24-47

600

$550-1,100

$500-970

2051

7,700

$73-140

$66-130

120

$29-56

$26-50

630

$580-1,100

$530-1,000

2052

8,000

$77-150

$69-130

120

$30-58

$27-53

650

$620-1,200

$550-1,100

2053

8,300

$80-160

$72-140

130

$32-61

$29-55

680

$650-1,200

$580-1,100

2054

8,600

$84-160

$75-150

130

$33-64

$30-58

700

$680-1,300

$610-1,200

2055

8,900

$88-170

$79-150

140

$35-67

$31-61

720

$710-1,400

$640-1,200

Present
Value

$640-1,300

$290-560

$250-500

$110-220

$5,000-9,800

$2,200-4,300

EAV

$34-66

$23-46

$13-26

$9.2-18

$260-510

$180-350

Table 7-14 Year-over-year monetized PIVh.s-related health benefits of Heavy-Duty Diesel and Heavy-Duty
Gasoline Vehicles (millions, 2021$) for the proposed program

HD Diesel Benefits HD Gasoline Benefits Combined Benefits

460

-------

3%
Discount
Rate

7%
Discount
Rate

3%
Discount
Rate

7%
Discount
Rate

3%
Discount
Rate

7%
Discount
Rate

2027

$15-31

$13-28

$8.3-18

$7.5-16

$23-49

$21-44

2028

$32-68

$29-61

$19-40

$17-36

$51-110

$46-97

2029

$54-110

$48-100

$33-68

$30-61

$87-180

$78-160

2030

$90-190

$81-170

$50-100

$45-93

$140-290

$130-260

2031

$150-310

$130-280

$74-150

$66-140

$220-460

$200-410

2032

$220-460

$200-410

$110-220

$95-190

$330-670

$290-610

2033

$300-610

$270-550

$140-290

$130-260

$440-900

$400-810

2034

$380-780

$340-700

$180-360

$160-320

$560-1,100

$500-1,000

2035

$470-950

$420-860

$220-440

$190-390

$690-1,400

$620-1,200

2036

$560-1,100

$510-1,000

$260-520

$230-470

$820-1,700

$740-1,500

2037

$660-1,300

$600-1,200

$300-600

$270-540

$970-1,900

$870-1,700

2038

$770-1,500

$690-1,400

$350-690

$310-620

$1,100-2,200

$1,000-2,000

2039

$860-1,700

$780-1,500

$390-780

$350-700

$1,300-2,500

$1,100-2,200

2040

$960-1,900

$860-1,700

$440-860

$390-780

$1,400-2,800

$1,300-2,500

2041

$1,000-2,100

$940-1,900

$480-950

$430-850

$1,500-3,000

$1,400-2,700

2042

$1,100-2,200

$1,000-2,000

$530-1,000

$470-930

$1,700-3,300

$1,500-2,900

2043

$1,200-2,400

$1,100-2,100

$570-1,100

$510-1,000

$1,800-3,500

$1,600-3,100

2044

$1,300-2,500

$1,100-2,200

$620-1,200

$550-1,100

$1,900-3,700

$1,700-3,300

2045

$1,300-2,600

$1,200-2,300

$660-1,300

$590-1,200

$2,000-3,900

$1,800-3,500

2046

$1,400-2,700

$1,200-2,400

$710-1,400

$630-1,200

$2,100-4,100

$1,900-3,700

2047

$1,400-2,800

$1,300-2,500

$750-1,500

$670-1,300

$2,200-4,300

$2,000-3,800

2048

$1,500-2,900

$1,300-2,600

$790-1,500

$710-1,400

$2,300-4,400

$2,000-4,000

2049

$1,500-2,900

$1,400-2,600

$840-1,600

$750-1,500

$2,300-4,600

$2,100-4,100

2050

$1,600-3,000

$1,400-2,700

$890-1,700

$800-1,500

$2,400-4,700

$2,200-4,300

2051

$1,600-3,100

$1,400-2,800

$930-1,800

$840-1,600

$2,500-4,900

$2,300-4,400

2052

$1,600-3,200

$1,500-2,800

$980-1,900

$880-1,700

$2,600-5,100

$2,400-4,600

2053

$1,700-3,200

$1,500-2,900

$1,000-2,000

$930-1,800

$2,700-5,200

$2,400-4,700

2054

$1,700-3,300

$1,500-3,000

$1,100-2,100

$970-1,900

$2,800-5,400

$2,500-4,800

2055

$1,700-3,400

$1,600-3,000

$1,100-2,200

$1,000-2,000

$2,900-5,500

$2,600-5,000

Present
Value

$15,000-30,000

$6,900-14,000

$8,000-16,000

$3,500-6,900

$23,000-46,000

$10,000-20,000

EAV

$790-1,600

$560-1,100

$420-820

$290-560

$1,200-2,400

$840-1,700

Table 7-15 Year-over-year monetized PIVh.s-related health benefits of Heavy-Duty Diesel and Heavy-Duty
Gasoline Vehicles (millions, 2021$) for the alternative program

HD Diesel Benefits

HD Gasoline Benefits

Combined Benefits

Discount

Rate

2027

$7.8-17

$7.0-15

$4.8-10

$4.3-9.0

$13-27

$11-24

2028

$20-41

$18-37

$13-26

$11-24

$32-67

$29-61

2029

$34-71

$31-64

$23-48

$21-43

$57-120

$51-110

2030

$63-130

$57-120

$37-76

$33-69

$100-210

$90-190

2031

$100-210

$93-190

$56-120

$50-100

$160-330

$140-300

2032

$160-320

$140-290

$81-160

$72-150

$240-490

$210-440

2033

$210-430

$190-390

$110-220

$96-200

$320-650

$290-590

2034

$270-550

$240-500

$130-270

$120-240

$410-820

$370-740

2035

$330-670

$300-610

$160-330

$150-300

$500-1,000

$450-900

2036

$400-810

$360-730

$190-390

$170-350

$600-1,200

$530-1,100

2037

$470-950

$420-850

$230-450

$200-410

$700-1,400

$630-1,300

2038

$550-1,100

$490-980

$260-520

$230-460

$800-1,600

$720-1,400

2039

$620-1,200

$550-1,100

$290-580

$260-520

$910-1,800

$820-1,600

2040

$680-1,400

$610-1,200

$320-640

$290-580

$1,000-2,000

$910-1,800

2041

$750-1,500

$670-1,300

$360-710

$320-630

$1,100-2,200

$990-2,000

2042

$810-1,600

$720-1,400

$390-770

$350-690

$1,200-2,400

$1,100-2,100

461

-------
2043

$860-1,700

$770-1,500

$420-830

$380-750

$1,300-2,500

$1,100-2,300

2044

$910-1,800

$810-1,600

$450-890

$410-800

$1,400-2,700

$1,200-2,400

2045

$950-1,900

$850-1,700

$490-950

$440-860

$1,400-2,800

$1,300-2,500

2046

$990-1,900

$890-1,700

$520-1,000

$470-910

$1,500-2,900

$1,400-2,700

2047

$1,000-2,000

$920-1,800

$550-1,100

$500-970

$1,600-3,100

$1,400-2,800

2048

$1,000-2,000

$940-1,800

$580-1,100

$520-1,000

$1,600-3,200

$1,500-2,900

2049

$1,100-2,100

$970-1,900

$620-1,200

$550-1,100

$1,700-3,300

$1,500-3,000

2050

$1,100-2,200

$990-1,900

$650-1,300

$590-1,100

$1,800-3,400

$1,600-3,100

2051

$1,100-2,200

$1,000-2,000

$690-1,300

$620-1,200

$1,800-3,500

$1,600-3,200

2052

$1,200-2,300

$1,000-2,000

$720-1,400

$650-1,300

$1,900-3,700

$1,700-3,300

2053

$1,200-2,300

$1,100-2,100

$760-1,500

$680-1,300

$2,000-3,800

$1,800-3,400

2054

$1,200-2,400

$1,100-2,100

$800-1,500

$720-1,400

$2,000-3,900

$1,800-3,500

2055

$1,200-2,400

$1,100-2,200

$830-1,600

$750-1,400

$2,100-4,000

$1,900-3,600

Present
Value

$11,000-21,000

$4,900-9,700

$5,900-12,000

$2,600-5,100

$17,000-33,000

$7,500-15,000

EAV

$570-1,100

$400-790

$310-600

$210-420

$870-1,700

$610-1,200

Table 7-16 Summary of the estimated tons of increased NOx, SO2 and direct PM2.5 per year from EGUs and
the associated monetized PIVh.s-related health impacts (millions, 2021$) for the proposed program

NOx

so2

Direct PM

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

2027

$(0.50)-(1.0)

$(0.45)-(0.93)

220

$(13)-(27)

$(12)-(25)

$(3.2)-(6.7)

$(2.8)-(6.0)

2028

140

$(1.1X2.3)

$(0.98)-(2.0)

480

$(28)-(60)

$(26)-(54)

$(7.0)-(15)

$(6.2)-(13)

2029

220

$(1.8)-(3.7)

$(1.6)-(3.4)

780

$(48)-(99)

$(43)-(89)

$(12)-(24)

$(10)-(22)

2030

440

$(3.7)-(7.6)

$(3.3)-(6.8)

1,600

$(97)-(200)

$(87)-(180)

190

$(24)-(49)

$(21)-(44)

2031

850

$(7.3)-( 15)

$(6.5)-(13)

3,000

$(190)-(390)

$(170)-(350)

360

$(47)-(96)

$(42)-(87)

2032

1,300

$(12)-(24)

$(11X22)

4,800

$(310X640)

$(280)-(570)

580

$(77)-(160)

$(69)-(140)

2033

1,800

$(17)-(33)

$(15)-(30)

6,500

$(430)-(890)

$(390)-(800)

800

$(110X220)

$(97)-(200)

2034

2,300

$(21)-(43)

$(19)-(39)

8,200

$(560)-(1100)

$(510)-(1000)

1,000

$(140)-(280)

$(130)-(250)

2035

2,800

$(26)-(53)

$(24)-(48)

9,900

$(690X1400)

$(630X1300)

1,200

$(170X350)

$(160X310)

2036

3,100

$(30)-(59)

$(27)-(54)

9,900

$(710)-(1400)

$(640)-(1300)

1,400

$(200)-(400)

$(180)-(360)

2037

3,400

$(33)-(65)

$(30)-(59)

9,400

$(680X1400)

$(610X1200)

1,500

$(220)-(440)

$(200)-(390)

2038

3,600

$(35)-(70)

$(32)-(63)

8,400

$(620)-(1200)

$(560)-(1100)

1,600

$(240)-(470)

$(210)-(430)

2039

3,700

$(37)-(74)

$(33)-(66)

7,000

$(530)-(1000)

$(470)-(940)

1,600

$(250)-(500)

$(230)-(450)

2040

3,800

$(39)-(76)

$(35)-(69)

5,100

$(390)-(780)

$(350)-(700)

1,700

$(260)-(520)

$(240)-(470)

2041

3,600

$(37)-(73)

$(33)-(65)

4,800

$(370)-(730)

$(330)-(660)

1,600

$(250)-(500)

$(230)-(450)

2042

3,400

$(34)-(67)

$(31)-(61)

4,400

$(340)-(670)

$(300)-(600)

1,500

$(240)-(470)

$(210X430)

2043

3,000

$(31)-(61)

$(28)-(55)

3,900

$(290)-(590)

$(270)-(520)

1,400

$(220)-(430)

$(190)-(390)

2044

2,700

$(27)-(53)

$(24)-(48)

3,200

$(250)-(490)

$(220)-(440)

1,200

$(190X380)

$(170X340)

2045

2,200

$(23)-(45)

$(20)-(40)

2,600

$(190X390)

$(180X350)

1,000

$(160X330)

$(150X300)

2046

2,000

$(20)-(39)

$(18)-(35)

2,300

$(170)-(340)

$(160)-(310)

990

$(160)-(310)

$(140)-(280)

2047

1,700

$(17)-(34)

$(15)-(30)

1,900

$(150X290)

$(130X260)

920

$(150X290)

$(130X260)

2048

1,400

$(14)-(27)

$(13)-(25)

1,600

$(120)-(240)

$(110)-(220)

850

$(130)-(270)

$(120)-(240)

2049

1,100

$(11X21)

$(9.7)-(19)

1,200

$(94)-(190)

$(84)-(170)

780

$(120X240)

$(110X220)

2050

740

$(7.5)-(15)

$(6.7)-(13)

850

$(65)-(130)

$(59)-(120)

700

$(110X220)

$(100X200)

2051

750

$(7.6)-(15)

$(6.8)-(13)

870

$(66)-(130)

$(60)-(120)

720

$(110)-(220)

$(100)-(200)

2052

760

$(7.8)-(15)

$(6.9)-(14)

880

$(67)-(130)

$(61)-(120)

730

$(110X230)

$(100X210)

2053

770

$(7.9)-( 15)

$(7X14)

890

$(68)-(140)

$(61)-(120)

730

$(120)-(230)

$(100)-(210)

2054

780

$(7.9)-(16)

$(7.1)-(14)

900

$(69)-(140)

$(62)-(120)

740

$(120X230)

$(110X210)

2055

790

$(8)-(16)

$(7.2)-(14)

910

$(70)-(140)

$(63)-(120)

750

$(120)-(240)

$(110)-(210)

Present
Value

$(340)-(680)

$(310)-(610)

$(5,300)-(l 1,000)

$(4,800)-(9,700)

$(2,600)-(5,100)

$(2,300)-(4,600)

EAV

$(18)-(35)

$(16)-(32)

$(280)-(560)

$(250)-(500)

$(130)-(270)

$(120)-(240)

462

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outcomes. All benefits estimates are rounded to two significant figures. Annual benefit values presented here are not discounted.
The present value of benefits is the total aggregated value of the series of discounted annual benefits that occur between 2027-2055
(in 2021 dollars) using either a 3% or 7% discount rate.

Table 7-17 Summary of the estimated tons of increased NOX, S02 and direct PM2.5 per year from EGUs and
the associated monetized PM2.5-related health impacts (millions, 2021$) for the alternative program

Nox

so2

Direct PM

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

Emissions
(tons)

3%
Discount
Rate

7%
Discount
Rate

2027

$(0.24)-(0.50)

$(0.21)-(0.45)

110

$(6.2>(13)

$(5.6)-(12)

$(1.5>(3.2)

$(1.3)-(2.9)

2028

$(0.6)-(1.3)

$(0.54>(1.1)

280

$(16)-(33)

$(14)-(30)

$(3.8)-(8.2)

$(3.4)-(7.3)

2029

140

$(l.l)-(2.2)

$(0.96)-(2.0)

480

$(28>(59)

$(25>(53)

$(6.8)-(14)

$(6.1>(13)

2030

330

$(2.6)-(5.4)

$(2.4)-(4.9)

1,100

$(68)-(140)

$(61)-(130)

140

$(17)-(35)

$(15X31)

2031

610

$(5.0)-(10)

$(4.5>(9.2)

2,100

$(130)-(270)

$(120)-(240)

260

$(32)-(66)

$(29)-(60)

2032

980

$(8.2)-(17)

$(7.4>(15)

3,400

$(210)-(440)

$(190)-(400)

420

$(53>(110)

$(47)-(98)

2033

1,300

$(ll)-(23)

$( 10>(21)

4,700

$(300)-(620)

$(270)-(560)

580

$(74)-(150)

$(67)-(140)

2034

1,700

$(15)-(30)

$(13>(27)

6,000

$(390)-(800)

$(350)-(720)

730

$(97)-(200)

$(87)-(180)

2035

2,100

$(18)-(37)

$(17)-(33)

7,200

$(480)-(990)

$(440)-(890)

890

$(120)-(240)

$(110)-(220)

2036

2,300

$(21 >(42)

$(19>(38)

7,200

$(500)-(1000)

$(450)-(900)

990

$(140)-(280)

$(120)-(250)

2037

2,500

$(23>(46)

$(21>(42)

6,900

$(480)-(970)

$(430)-(870)

1,100

$(150)-(310)

$(140)-(280)

2038

2,600

$(25>(50)

$(22)-(45)

6,100

$(440)-(880)

$(390)-(790)

1,100

$(170)-(330)

$(150)-(300)

2039

2,700

$(26>(52)

$(24)-(47)

5,100

$(370)-(740)

$(330)-(670)

1,200

$(180)-(350)

$(160)-(320)

2040

2,800

$(27>(54)

$(25)-(49)

3,800

$(280)-(550)

$(250)-(500)

1,200

$(180)-(370)

$(170)-(330)

2041

2,600

$(27>(52)

$(24)-(47)

3,500

$(260)-(530)

$(240)-(470)

1,200

$(180)-(360)

$(160)-(320)

2042

2,500

$(25>(49)

$(22)-(44)

3,200

$(240)-(490)

$(220)-(440)

1,100

$(170)-(340)

$(160)-(310)

2043

2,200

$(23>(44)

$(20)-(40)

2,800

$(220)-(430)

$(190)-(380)

1,000

$(160)-(310)

$(140)-(280)

2044

1,900

$(20>(39)

$(18>(35)

2,400

$(180)-(360)

$(160)-(320)

890

$(140)-(280)

$(130)-(250)

2045

1,600

$(17)-(32)

$(15)-(29)

1,900

$(140)-(280)

$(130)-(250)

760

$(120)-(240)

$(110)-(220)

2046

1,400

$(15>(29)

$(13>(26)

1,600

$(130)-(250)

$(110)-(220)

720

$(110)-(230)

$(100)-(200)

2047

1,200

$(13)-(25)

$(11 >(22)

1,400

$(110)-(210)

$(97)-(190)

670

$(110)-(210)

$(96)-(190)

2048

1,000

$( 10>(20)

$(9.2)-(18)

1,200

$(88)-(180)

$(79)-(160)

620

$(98)-(200)

$(88)-(180)

2049

780

$(7.9>(16)

$(7.1>(14)

890

$(68)-(140)

$(61)-(120)

570

$(90)-(180)

$(81)-(160)

2050

540

$(5.5>(11)

$(4.9)-(9.7)

620

$(48)-(95)

$(43)-(85)

510

$(81)-(160)

$(73)-(150)

2051

550

$(5.6>(11)

$(5.0)-(9.9)

630

$(48)-(96)

$(44)-(86)

520

$(83)-(160)

$(74)-(150)

2052

560

$(5.7>(11)

$(5.1>(10)

640

$(49)-(98)

$(44)-(87)

530

$(84)-(170)

$(75)-(150)

2053

560

$(5.7>(11)

$(5.1)-(10)

650

$(50>(99)

$(45>(89)

540

$(85)-(170)

$(76>(150)

2054

570

$(5.8>(11)

$(5.2>(10)

660

$(50)-(100)

$(45>(90)

540

$(86)-(170)

$(77)-(150)

2055

570

$(5.9>(11)

$(5.2)-(10)

670

$(51>(100)

$(46)-(91)

550

$(87)-(170)

$(78)-(160)

Present
Value

$(240)-(480)

$(220)-(440)

$(3,800)-(7,600)

$(3,400)-(6,800)

$(l,800)-(3,600)

$(l,600)-(3,300)

EAV

$(13>(25)

$(11X23)

$(200)-(400)

$(180)-(360)

$(95)-(190)

$(85)-(170)

Notes: The range of benefits in this table reflect the range of premature mortality estimates derived from the Medicare study (Wu et
al., 2020) and the NHIS study (Pope III et al., 2019). A negative benefit value (in parentheses) implies an increase in adverse health
outcomes. All benefits estimates are rounded to two significant figures. Annual benefit values presented here are not discounted. The
present value of benefits is the total aggregated value of the series of discounted annual benefits that occur between 2027-2055 (in
2021 dollars) using either a 3% or 7% discount rate.

463

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Table 7-18 Year-over-year monetized PM2.5-related health benefits (millions, 2021$) of Onroad Heavy-Duty
Vehicle emissions, increased emissions from EGUs and net benefits from the proposed program

Total On-Road Benefits

EGU Upstream Benefits

Net Benefits

Discount Rate

2027

$23-49

$21-44

$(17)-(35)

$(15)-(32)

$6.4-13

$5.7-12

2028

$51-110

$46-97

$(37)-(76)

$(33)-(69)

$15-31

$13-28

2029

$87-180

$78-160

$(61)-(130)

$(55)-(110)

$26-53

$23-48

2030

$140-290

$130-260

$(120)-(260)

$(110)-(230)

$16-33

$14-30

2031

$220-460

$200-410

$(240)-(500)

$(220)-(450)

$(22)-(45)

$(20)-(40)

2032

$330-670

$290-610

$(400)-(820)

$(360)-(730)

$(70)-(140)

$(64)-(130)

2033

$440-900

$400-810

$(560)-(l,100)

$(500)-(l,000)

$(120)-(240)

$(110)-(210)

2034

$560-1,100

$500-1,000

$(720)-(l,500)

$(650)-(l,300)

$(160)-(330)

$(150)-(300)

2035

$690-1,400

$620-1,200

$(890)-(l,800)

$(800)-(l,600)

$(210)-(410)

$(190)-(370)

2036

$820-1,700

$740-1,500

$(930)-(l,900)

$(840)-(l,700)

$(110)-(220)

$(100)-(200)

2037

$970-1,900

$870-1,700

$(930)-(l,900)

$(840)-(l,700)

$31-62

$27-57

2038

$1,100-2,200

$1,000-2,000

$(890)-(l,800)

$(800)-(l,600)

$220-440

$200-400

2039

$1,300-2,500

$1,100-2,200

$(810)-(1,600)

$(730)-(l,500)

$440-880

$400-790

2040

$1,400-2,800

$1,300-2,500

$(700)-(l,400)

$(630)-(l,200)

$700-1,400

$630-1,300

2041

$1,500-3,000

$1,400-2,700

$(660)-(l,300)

$(590)-(l,200)

$870-1,700

$780-1,500

2042

$1,700-3,300

$1,500-2,900

$(610)-(1,200)

$(5 50)-(l, 100)

$1,000-2,100

$940-1,900

2043

$1,800-3,500

$1,600-3,100

$(540)-(l,100)

$(490)-(970)

$1,200-2,400

$1,100-2,200

2044

$1,900-3,700

$1,700-3,300

$(470)-(930)

$(420)-(830)

$1,400-2,800

$1,300-2,500

2045

$2,000-3,900

$1,800-3,500

$(380)-(760)

$(340)-(680)

$1,600-3,100

$1,400-2,800

2046

$2,100-4,100

$1,900-3,700

$(350)-(690)

$(310)-(620)

$1,700-3,400

$1,600-3,100

2047

$2,200-4,300

$2,000-3,800

$(310)-(620)

$(280)-(550)

$1,900-3,600

$1,700-3,300

2048

$2,300-4,400

$2,000-4,000

$(270)-(540)

$(240)-(480)

$2,000-3,900

$1,800-3,500

2049

$2,300-4,600

$2,100-4,100

$(230)-(450)

$(200)-(410)

$2,100-4,100

$1,900-3,700

2050

$2,400-4,700

$2,200-4,300

$(180)-(370)

$(170)-(330)

$2,300-4,400

$2,000-3,900

2051

$2,500-4,900

$2,300-4,400

$(190)-(370)

$(170)-(330)

$2,300-4,500

$2,100-4,100

2052

$2,600-5,100

$2,400-4,600

$(190)-(380)

$(170)-(340)

$2,400-4,700

$2,200-4,200

2053

$2,700-5,200

$2,400-4,700

$(190)-(380)

$(170)-(340)

$2,500-4,800

$2,300-4,400

2054

$2,800-5,400

$2,500-4,800

$(190)-(390)

$(170)-(350)

$2,600-5,000

$2,300-4,500

2055

$2,900-5,500

$2,600-5,000

$(200)-(390)

$(180)-(350)

$2,700-5,200

$2,400-4,600

Present
Value

$23,000-46,000

$10,000-20,000

$(8,200)-(17,000)

$(4,600)-(9,300)

$15,000-29,000

$5,800-11,000

EAV

$1,200-2,400

$840-1,700

$(430)-(860)

$(380)-(760)

$780-1,500

$470-910

Notes: The range of benefits in this table reflect the range of premature mortality estimates derived from the
Medicare study (Wu et al., 2020) and the NHIS study (Pope III et al., 2019). All benefits estimates are rounded to
two significant figures. Annual benefit values presented here are not discounted. Negative values in parentheses
are health disbenefits related to increases in estimated emissions. The present value of benefits is the total
aggregated value of the series of discounted annual benefits that occur between 2027-2055 (in 2021 dollars) using
either a 3% or 7% discount rate. The benefits associated with the standards presented here do not include health
benefits associated with reduced criteria pollutant emissions from refineries. The benefits in this table also do not
include the full complement of health and environmental benefits that, if quantified and monetized, would
increase the total monetized benefits.

Table 7-19 Year-over-year monetized PIVh.s-related health benefits (millions, 2021$) of Onroad Heavy-Duty
Vehicle emissions, increased emissions from EGUs, and net benefits from the alternative program

Total On-Road Benefits

EGU Upstream Benefits

Net Benefits

3%
Discount
Rate

7%
Discount
Rate

3%
Discount
Rate

7%
Discount
Rate

3%
Discount
Rate

7%
Discount
Rate

2027

$13-27

$11-24

$(7.9)-(17)

$(7.1)-(15)

$4.7-9.6

$4.2-8.7

2028

$32-67

$29-61

$(20)-(43)

$(18)-(38)

$12-25

$11-22

2029

$57-120

$51-110

$(36)-(75)

$(32)-(68)

$22-44

$19-40

2030

$100-210

$90-190

$(88)-(180)

$(79)-(170)

$12-24

$11-21

2031

$160-330

$140-300

$(170)-(350)

$( 150)-(310)

$(6.8)-(18)

$(6.2)-(16)

2032

$240-490

$210-440

$(280)-(570)

$(250)-(510)

$(37)-(82)

$(34)-(74)

2033

$320-650

$290-590

$(390)-(800)

$(350)-(720)

$(67)-(150)

$(61)-(130)

2034

$410-820

$370-740

$(500)-(1000)

$(450)-(930)

$(97)-(210)

$(88)-(190)

2035

$500-1,000

$450-900

$(620)-(1300)

$(560)-(1100)

$(120)-(260)

$( 110)-(240)

464

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2036

$600-1,200

$530-1,100

$(650)-(1300)

$(590)-(1200)

$(57)-(130)

$(53)-(110)

2037

$700-1,400

$630-1,300

$(660)-(1300)

$(590)-(1200)

$42-76

$37-67

2038

$800-1,600

$720-1,400

$(630)-(1300)

$(570)-(l 100)

$180-340

$160-310

2039

$910-1,800

$820-1,600

$(570)-(l 100)

$(510)-(1000)

$340-660

$300-590

2040

$1,000-2,000

$910-1,800

$(490)-(980)

$(440)-(880)

$520-1,000

$470-920

2041

$1,100-2,200

$990-2,000

$(470)-(940)

$(420)-(840)

$630-1,200

$570-1,100

2042

$1,200-2,400

$1,100-2,100

$(440)-(880)

$(400)-(790)

$750-1,500

$680-1,300

2043

$1,300-2,500

$1,100-2,300

$(400)-(790)

$(360)-(710)

$880-1,700

$790-1,600

2044

$1,400-2,700

$1,200-2,400

$(340)-(680)

$(310)-(610)

$1,000-2,000

$920-1,800

2045

$1,400-2,800

$1,300-2,500

$(280)-(550)

$(250)-(500)

$1,200-2,300

$1,000-2,000

2046

$1,500-2,900

$1,400-2,700

$(250)-(510)

$(230)-(450)

$1,300-2,400

$1,100-2,200

2047

$1,600-3,100

$1,400-2,800

$(230)-(450)

$(200)-(400)

$1,300-2,600

$1,200-2,400

2048

$1,600-3,200

$1,500-2,900

$(200)-(390)

$(180)-(350)

$1,400-2,800

$1,300-2,500

2049

$1,700-3,300

$1,500-3,000

$(170)-(330)

$(150)-(300)

$1,500-3,000

$1,400-2,700

2050

$1,800-3,400

$1,600-3,100

$(130)-(270)

$(120)-(240)

$1,600-3,100

$1,500-2,800

2051

$1,800-3,500

$1,600-3,200

$(140)-(270)

$(120)-(240)

$1,700-3,300

$1,500-2,900

2052

$1,900-3,700

$1,700-3,300

$(140)-(280)

$(120)-(250)

$1,800-3,400

$1,600-3,000

2053

$2,000-3,800

$1,800-3,400

$(140)-(280)

$(130)-(250)

$1,800-3,500

$1,600-3,100

2054

$2,000-3,900

$1,800-3,500

$(140)-(280)

$(130)-(250)

$1,900-3,600

$1,700-3,200

2055

$2,100-4,000

$1,900-3,600

$(140)-(290)

$(130)-(260)

$1,900-3,700

$1,700-3,300

Present
Value

$17,000-33,000

$7,500-15,000

$(5,800)-(12,000)

$(3,200)-(6,600)

$11,000-21,000

$4,200-8,200

EAV

$870-1,700

$610-1,200

$(300)-(610)

$(260)-(530)

$570-1,100

$340-670

Notes: The range of benefits in this table reflect the range of premature mortality estimates derived from the
Medicare study (Wu et al., 2020) and the NHIS study (Pope III et al., 2019). All benefits estimates are rounded to
two significant figures. Annual benefit values presented here are not discounted. Negative values in parentheses
are health disbenefits related to increases in estimated emissions. The present value of benefits is the total
aggregated value of the series of discounted annual benefits that occur between 2027-2055 (in 2021 dollars) using
either a 3% or 7% discount rate. The benefits associated with the standards presented here do not include health
benefits associated with reduced criteria pollutant emissions from refineries. The benefits in this table also do not
include the full complement of health and environmental benefits that, if quantified and monetized, would
increase the total monetized benefits.

7.2.5 Characterizing Uncertainty in the Estimated Benefits

There are likely to be sources of uncertainty in any complex analysis using estimated
parameters and inputs from numerous models, including this analysis. The Benefits TSD that
accompanied the 2023 PM NAAQS Reconsideration Proposal details our approach to
characterizing uncertainty in both quantitative and qualitative terms. That TSD describes the
sources of uncertainty associated with key input parameters including emissions inventories, air
quality data from models (with their associated parameters and inputs), population data,
population estimates, health effect estimates from epidemiology studies, economic data for
monetizing benefits, and assumptions regarding the future state of the country (i.e., regulations,
technology, and human behavior). Each of these inputs is uncertain and affects the size and
distribution of the estimated benefits.

The BPT approach is a simplified approach that relies on additional assumptions and has its
own limitations, some of which are described in Section 7.2.6. We plan to consider a more
complete assessment of benefits in future rulemakings. Additional uncertainties related to key
assumptions underlying the estimates for PIVh.s-related premature mortality described in Section
7.2.2 of this chapter include the following:

• We assume that all fine particles, regardless of their chemical composition, are equally
potent in causing premature mortality. This is an important assumption because PM2.5
varies considerably in composition across sources, but the scientific evidence is not yet

465

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sufficient to allow differentiation of effect estimates by particle type. The PM ISA, which
was reviewed by CASAC, concluded that "across exposure durations and health effects
categories ... the evidence does not indicate that any one source or component is
consistently more strongly related with health effects than PM2.5 mass."37

• We assume that the health impact function for fine particles is log-linear down to the
lowest air quality levels modeled in this analysis. Thus, the estimates include health
benefits from reducing fine particles in areas with varied concentrations of PM2.5,
including both regions that are in attainment with the fine particle standard and those that
do not meet the standard down to the lowest modeled concentrations. The PM ISA
concluded that "the majority of evidence continues to indicate a linear, no-threshold
concentration-response relationship for long-term exposure to PM2.5 and total
(nonaccidental) mortality."38

• We assume that there is a "cessation" lag between the change in PM exposures and the
total realization of changes in mortality effects. Specifically, we assume that some of the
incidences of premature mortality related to PM2.5 exposures occur in a distributed
fashion over the 20 years following exposure based on the advice of the SAB-HES,
which affects the valuation of mortality benefits at different discount rates. The above
assumptions are subject to uncertainty.39 Similarly, we assume there is a cessation lag
between the change in PM exposures and both the development and diagnosis of lung
cancer.

7.2.6 Benefit-per-Ton Estimate Limitations

All BPT estimates have inherent limitations. One limitation of using the PM2.5-related BPT
approach is an inability to provide estimates of the health and welfare benefits associated with
exposure to ozone, welfare benefits and some unquantified health benefits associated with PM2.5,
as well as health and welfare benefits associated with ambient NO2 and SO2. Table 7-20 presents
a selection of unquantified criteria pollutant health and welfare benefits categories. Another
limitation is that the mobile sector-specific air quality modeling that underlies the PM2.5 BPT
value did not provide estimates of the PM2.5-related benefits associated with reducing VOC
emissions, but these unquantified benefits are generally small compared to benefits associated
with other PM2.5 precursors.

Table 7-20 Unquantified Criteria Pollutant Health and Welfare Benefits Categories