REDUCING FUEL CONSUMPTION
AND GREENHOUSE GAS
EMISSIONS OF MEDIUM-
AND HEAVY-DUTY
VEHICLES, PHASE TWO
Final Report
Committee on Assessment of Technologies and Approaches for Reducing
the Fuel Consumption of Medium- and Heavy-Duty Vehicles, Phase Two
Board on Energy and Environmental Systems
Division on Engineering and Physical Sciences
Transportation Research Board
A Consensus Study Report of
THE NATIONAL ACADEMIES PRESS
Washington, DC
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This activity was supported by cooperative agreement DTNH22-12-H-00389 from the U.S. Department of Transportation National Highway Traffic Safety Administration and the Presidents’ Committee of the National Academies of Sciences, Engineering, and Medicine. Any opinions, findings, conclusions, or recommendations expressed in this publication do not necessarily reflect the views of any organization or agency that provided support for the project.
International Standard Book Number-13: 978-0-309-49635-3
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Digital Object Identifier: https://doi.org/10.17226/25542
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Suggested citation: National Academies of Sciences, Engineering, and Medicine. 2020. Reducing the Fuel Consumption and Greenhouse Gas Emissions of Medium- and Heavy-Duty Vehicles, Phase Two: Final Report. Washington, DC: The National Academies Press. https://doi.org/10.17226/25542.
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COMMITTEE ON ASSESSMENT OF TECHNOLOGIES AND APPROACHES FOR REDUCING THE FUEL CONSUMPTION OF MEDIUM- AND HEAVY-DUTY VEHICLES, PHASE TWO
Andrew Brown, Jr., NAE,1 Delphi Corporation (ret.), Troy, MI, Chair
Inês Azevedo, Stanford University, Stanford, CA
Rodica Baranescu, NAE, University of Illinois, Chicago, IL
Tom Cackette, California Air Resources Board (ret.), Sacramento, CA
Nigel Clark, West Virginia University, Morgantown, WV
Ronald Graves, Oak Ridge National Laboratory, Knoxville, TN
Daniel Hancock, NAE, General Motors (ret.), Indianapolis, IN
W. Michael Hanemann, NAS,2 Arizona State University, Tempe, AZ
Winston Harrington, Resources for the Future, Washington, DC
Gary Marchant, Arizona State University, Tempe, AZ
Paul Menig, Tech-I-M, Sherwood, OR
Amelia Regan, University of California, Irvine, CA (resigned February 2017)
Mike Roeth, North American Council for Freight Efficiency, Fort Wayne, IN
Gary Rogers, Roush Industries Inc., Livonia, MI
Chuck Salter, Independent Consultant (ret.), Chambersburg, PA
Christine Vujovich, Cummins, Inc. (ret.), Columbus, IN
John Woodrooffe, University of Michigan Transportation Research Institute (ret.), Ann Arbor, MI
Martin Zimmerman, University of Michigan (ret.), Ann Arbor, MI
Staff
Elizabeth Zeitler, Study Director, Senior Program Officer, Board on Energy and Environmental Systems (beginning December, 2017)
Martin Offutt, Study Director, Senior Program Officer, Board on Energy and Environmental Systems (until December, 2017)
Dana Caines, Financial Manager, Board on Energy and Environmental Systems
Rebecca DeBoer, Program Assistant, Board on Energy and Environmental Systems
Lanita Jones, Administrative Coordinator, Board on Energy and Environmental Systems
Michaela Kerxhalli-Kleinfield, Research Assistant, Board on Energy and Environmental Systems
Joseph Morris, Senior Program Officer, Transportation Research Board
Janki Patel, Research Associate, Board on Energy and Environmental Systems
E. Jonathan Yanger, Research Associate, Board on Energy and Environmental Systems
James Zucchetto, Senior Scientist, Board on Energy and Environmental Systems
NOTE: See Appendix B, Disclosure of Conflict(s) of Interest.
___________________
1 NAE, National Academy of Engineering.
2 NAS, National Academy of Sciences.
BOARD ON ENERGY AND ENVIRONMENTAL SYSTEMS
Jared Cohon, NAE,1 Carnegie Mellon University, Pittsburgh, PA, Chair
David Allen, NAE, University of Texas, Austin, TX
Vicky Bailey, Anderson Stratton Enterprises, Washington, DC
Carla Bailo, Center for Automotive Research, Ann Arbor, MI
W. Terry Boston, NAE, GridLiance GP, LLC and Grid Protection Alliance, Chattanooga, TN
William Brinkman, NAS,2 Princeton University, Princeton, NJ
Deepakraj Divan, NAE, Georgia Institute of Technology, Atlanta, GA
Marcius Extavour, XPRIZE, Culver City, CA
TJ Glauthier, TJ Glauthier Associates, LLC, Moss Beach, CA
Nat Goldhaber, Claremont Creek Ventures, Berkeley, CA
Barbara Kates-Garnick, Tufts University, Boston, MA
JoAnn Milliken, Independent Consultant, Alexandria, VA
Dorothy Robyn, Boston University, Washington, DC
Kelly Sims-Gallagher, The Fletcher School, Tufts University, Medford, MA
Alexander Slocum, NAE, Massachusetts Institute of Technology, Cambridge, MA
John Wall, NAE, Cummins Inc (retired), Belvedere, CA
Robert Weisenmiller, California Energy Commission (former), Sacramento, CA
Staff
K. John Holmes, Director/Scholar
Heather Lozowski, Financial Manager
Rebecca DeBoer, Program Assistant
Michaela Kerxhalli-Kleinfield, Research Assistant
Ben A. Wender, Senior Program Officer
Elizabeth Zeitler, Senior Program Officer
James Zucchetto, Senior Scientist
___________________
1 NAE, National Academy of Engineering.
2 NAS, National Academy of Sciences.
TRANSPORTATION RESEARCH BOARD 2019 EXECUTIVE COMMITTEE
Victoria A. Arroyo, Executive Director, Georgetown Climate Center; Assistant Dean, Centers and Institutes; and Professor and Director, Environmental Law Program, Georgetown University Law Center, Washington, DC, Chair
Leslie S. Richards, Secretary, Pennsylvania Department of Transportation, Harrisburg, PA, Vice Chair
Neil J. Pedersen, Transportation Research Board, Executive Director
Members
Michael F. Ableson, Vice President, Global Strategy, General Motors Company, Detroit, MI
Carlos M. Braceras, Executive Director, Utah Department of Transportation, Salt Lake City, UT
Ginger Evans, President, Tower Consulting, LLC, Arlington, VA
Nuria I. Fernandez, General Manager/CEO, Santa Clara Valley Transportation Authority, San Jose, CA
Nathaniel P. Ford, Sr., Executive Director–CEO, Jacksonville Transportation Authority, Jacksonville, FL
A. Stewart Fotheringham, Professor, School of Geographical Sciences and Urban Planning, Arizona State University, Tempe, AZ
Diane Gutierrez-Scaccetti, Commissioner, New Jersey Department of Transportation, Ewing, NJ
Susan Hanson, Distinguished University Professor Emerita, Graduate School of Geography, Clark University, Worcester, MA
Stephen W. Hargarten, Professor of Emergency Medicine, Medical College of Wisconsin, Milwaukee, WI
Chris T. Hendrickson, Hamerschlag University Professor of Engineering, Carnegie Mellon University, Pittsburgh, PA
S. Jack Hu, Vice President for Research and J. Reid and Polly Anderson Professor of Manufacturing, University of Michigan, Ann Arbor, MI
Roger B. Huff, President, HGLC, LLC, Farmington Hills, MI
Ashby Johnson, Executive Director, Capital Area Metropolitan Planning Organization (CAMPO), Austin, TX
Geraldine Knatz, Professor, Sol Price School of Public Policy, Viterbi School of Engineering, University of Southern California, Los Angeles, CA
William Kruger, Vice President, UPS Freight for Fleet Maintenance and Engineering, Richmond, VA
Julie Lorenz, Secretary, Kansas Department of Transportation, Topeka, KS
Michael R. McClellan, Vice President, Strategic and Network Planning, Norfolk Southern Corporation, Norfolk, VA
Margaret Melinda McGrath, Executive Director, Mississippi Department of Transportation, Jackson, MS
Patrick K. McKenna, Director, Missouri Department of Transportation, Jefferson City, MO
Brian Ness, Director, Idaho Transportation Department, Boise, ID
Susan A. Shaheen, Adjunct Professor, Co-Director, Transportation Sustainability Research Center, University of California, Berkeley, CA
James M. Tien, Distinguished Professor and Dean Emeritus, College of Engineering, University of Miami, Coral Gables, FL
Shawn Wilson, Secretary, Louisiana Department of Transportation and Development, Baton Rouge, LA
Ex Officio Members
Ronald Batory, Administrator, Federal Railroad Administration, U.S. Department of Transportation, Washington, DC
Michael R. Berube, Deputy Assistant Secretary for Sustainable Transportation, U.S. Department of Energy, Washington, DC
Mark H. Buzby (Rear Admiral, U.S. Navy), Administrator, Maritime Administration, U.S. Department of Transportation, Washington, DC
Steven Cliff, Deputy Executive Officer, California Air Resources Board, Sacramento, CA
Edward N. Comstock, Independent Naval Architect, Sunbury, MA
Howard R. Elliott, Administrator, Pipeline and Hazardous Materials Safety Administration, U.S. Department of Transportation, Washington, DC
Daniel K. Elwell, Acting Administrator, Federal Aviation Administration, U.S. Department of Transportation, Washington, DC
Diana Furchtgott-Roth, Assistant Secretary for Research and Technology, Office of the Secretary of Transportation, Washington, DC
LeRoy Gishi, Chief, Division of Transportation, Bureau of Indian Affairs, U.S. Department of the Interior, Germantown, MD
John T. Gray II, Senior Vice President, Policy and Economics, Association of American Railroads, Washington, DC
Nikola Ivanov, Director of Operations, Center for Advanced Transportation Technology Laboratory, University of Maryland, College Park, and Chair, TRB Young Members Council
Heidi King, Deputy Administrator and Acting Administrator, National Highway Traffic Safety Administration, U.S. Department of Transportation, Washington, DC
Raymond Martinez, Administrator, Federal Motor Carrier Safety Administration, Washington, DC
Nicole Nason, Administrator, Federal Highway Administration, U.S. Department of Transportation, Washington, DC
Craig A. Rutland, U.S. Air Force Pavement Engineer, U.S. Air Force Civil Engineer Center, Tyndall Air Force Base, FL
Karl Schultz (Admiral, U.S. Coast Guard), Commandant, U.S. Coast Guard, Washington, DC
Karl Simon, Director, Transportation and Climate Division, U.S. Environmental Protection Agency, Washington, DC
Paul Skoutelas, President and CEO, American Public Transportation Association, Washington, DC
Scott A. Spellmon (Major General, U.S. Army), Deputy Commanding General for Civil and Emergency Operations, U.S. Army Corps of Engineers, Washington, DC
Katherine F. Turnbull, Executive Associate Director and Research Scientist, Texas A&M Transportation Institute, College Station, TX
Jim Tymon, Executive Director, American Association of State Highway and Transportation Officials, Washington, DC
K. Jane Williams, Acting Administrator, Federal Transit Administration, U.S. Department of Transportation, Washington, DC
Preface
The fuel consumption and greenhouse gas (GHG) emissions of medium- and heavy-duty vehicles (MHDVs) have become a focus of legislative and regulatory action, starting with the Energy Independence and Security Act of 2007 (EISA), P.L. 110-140. Section 101 of EISA mandated the U.S. Department of Transportation to promulgate fuel consumption standards for MHDVs for the first time. In addition, Section 108 of that same Act required the secretary of transportation to contract with the National Academy of Sciences to undertake a study on the technologies and costs for improving fuel consumption in MHDVs and include a follow-on report at 5-year intervals.
In response to the secretary’s request, the National Research Council1 (NRC) in 2010 completed Technologies and Approaches to Reducing the Fuel Consumption of Medium- and Heavy-Duty Vehicles, referred to henceforth as the “NRC Phase One Report.” The NRC Phase One Report provided findings and recommendations on the following: the development of a fuel consumption program for MHDVs; metrics for measuring MHDV fuel consumption; availability and costs of various technologies for reducing fuel consumption; potential indirect effects and externalities associated with fuel consumption standards for MHDVs; alternatives for the scope, stringency, certification methods, and compliance approach for the standards; and a suggested demonstration program to validate innovative certification procedures and regulatory elements. Thereafter, in 2011, the National Highway Traffic Safety Administration (NHTSA) and the U.S. Environmental Protection Agency (EPA) issued the “Phase I rule” on fuel consumption and GHG emissions of MHDVs.
In March 2013, the NRC initiated the Phase Two Study, the first 5-year follow-on to the NRC’s 2010 Phase One Report, called for in EISA. The NRC Phase Two Study includes the present report, as well as a first report issued in April 2014 titled Reducing the Fuel Consumption and Greenhouse Gas Emissions of Medium- and Heavy-Duty Vehicles, Phase Two: First Report. The sponsoring agency had requested the committee provide advice on the then-pending revision to the Phase I rule. At the time of the 2014 NRC Phase Two Study, First Report, NHTSA was revising its regulatory regime with three objectives: (1) reducing in-use emissions of carbon dioxide from MHDVs; (2) reducing in-use emissions of other GHGs from MHDVs; and (3) improving in-use efficiency of fuel use in MHDVs—by driving innovation, advancement, adoption, and in-use balance of technology through regulation. The 2014 report advised on pathways to accomplish this, subject to the following constraints provided by NHTSA: (a) holding life-cycle cost of technology change or technology addition to an acceptable level; (b) holding capital
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1 Effective July 1, 2015, the institution is called the National Academies of Sciences, Engineering, and Medicine. References in this report to the National Research Council are used in a historical context identifying programs prior to July 1, 2015.
cost of acquiring required new technology to an acceptable level; (c) acknowledging the importance of employing a balance of energy resources that offers national security; (d) avoiding near-term, precipitous regulatory changes that are disruptive to commercial planning; (e) ensuring that the vehicles offered for sale remain suited to their intended purposes and meet user requirements; (f) ensuring that the process used to demonstrate compliance is accurate, efficient, and not excessively burdensome; and (g) not eroding control of criteria pollutants or unregulated species that may have health effects.
The present report is the second and final report of the NRC Phase Two Study. At the request of the sponsoring agency, the committee took account of the August 2016 publication of the Phase II rule on fuel consumption and GHGs. The new rule was supported by extensive analysis, and the committee has weighed this in the development of this report, concerned as it is with possible technological and policy developments out to 2030. This longer time frame freed up the committee to envision more dramatic technological developments affecting the engine and vehicle as well as possible changes to the goods movement enterprise and to regulatory and compliance alternatives. At the same time, the committee has considered near-term improvements to the current power plants—to diesel compression-ignition and spark-ignition internal combustion engines—including the possibility of incorporating hybrid energy storage and drives. Many of the constraints the committee noted in the context of its first report in 2014 still prevail: To pick one example, the committee has considered the costs and benefits of compliance with the Phase II rule and looked in some depth at constraints (a) and (b).
The committee is grateful to all of the federal agencies, original equipment manufacturers and suppliers and their respective associations, and nongovernmental organizations who contributed significantly of their time and efforts to this study, either by giving presentations at meetings or by responding to committee requests for information. We acknowledge the valuable contributions of individuals and organizations that provided information and made presentations at our meetings in Appendix C.
As a final check on the quality and objectivity of the study, all National Academies reports whether products of studies, summaries of workshop proceedings, or other documents must undergo a rigorous, independent external review by experts whose comments are provided anonymously to the committee members. The review process is structured to ensure that each report addresses its approved study charge and does not go beyond it, that the findings are supported by the scientific evidence and arguments presented, that the exposition and organization are effective, and that the report is impartial and objective. We wish to thank the following individuals for their review of this report:
Ewa Bardasz, Zual Associates in Lubrication LLC, Mentor, OH
R. Steven Berry, University of Chicago, Aspen, CO
Rob Brenner, Air Policy Office, EPA (Retired), Arlington, VA
Rebecca Brewster, American Transportation Research Institute, Marietta, GA
Alessandro Faldi, ExxonMobil Research and Engineering Company, Irving, TX
Georgios Fontaras, European Commission, Joint Research Center, Ispra, Italy
Arthur Fraas, Resources for the Future, Washington DC
Thomas Jahns, University of Wisconsin–Madison, Madison, WI
John Johnson, Michigan Technological University, Houghton, MI
Jim Kesseli, Brayton Energy, Hampton, NH
Steve Kratzke, National Highway Traffic Safety Administration, Rockville, MD
Rolf D. Reitz, University of Wisconsin–Madison, Madison, WI
Dorothy Robyn, Independent Consultant, Washington, DC
Aymeric Rousseau, Argonne National Laboratory, Argonne, IL
Although the reviewers listed above have provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations nor did they see the final draft of the report before its release. The review of this report was overseen by ELISABETH DRAKE, Massachusetts Institute of Technology, and CHRIS HENDRICKSON, Carnegie Mellon University, who were responsible for making certain that an
independent examination of this report was carried out in accordance with institutional procedures and that all review comments were carefully considered. Responsibility for the final content of this report rests entirely with the authoring committee and the institution.
The MHDVII Committee delivered this report in October 2019. It relies on work conducted through December 31, 2017. Our original intent was to deliver the report by March 2018. However, a prolonged lapse of funding from the study sponsor regrettably resulted in an extended delay in the completion of the committee report. Nevertheless, the committee firmly believes its work is meaningful, and remains current and objective. The report provides findings and recommendations that multiple interested communities will find valuable and actionable in their endeavors. Section 101 of the EISA 2007 directs the U.S. Department of Transportation to commission the National Academies to undertake studies on the technologies and costs for improving fuel consumption in MHDVs at 5-year intervals. Since initiation of the next (third) study phase is imminent, this report also highlights areas, topics, technologies, and issues for future examination. We hope the next committee will consider them in their deliberations.
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Contents
2 Setting the Stage: Regulatory Horizons, Challenges, and Influences
2.1. Future Regulatory Pathways
2.1.1 Fleet Characteristics During the Phase III Standards Time Horizon
2.1.2 Assessing the GHG Reductions and Fuel Savings Potential
2.1.3 Timing: An Opportunity and a Challenge for the Phase III Rulemaking
2.2. Key Regulatory Gaps and Challenges
2.2.3 Factors Other than Engine/Powertrain Affecting Fuel Consumption/GHG Emissions
2.2.4 Complexity and Variety of Vehicle Types
2.2.5 Large Versus Small Companies
2.2.6 Life-Cycle Analysis of Vehicle/Fuel Systems
2.2.7 Certification and Real-World Compliance
2.2.8 Regulatory Baselines and Metrics
2.2.9 Other Factors Affecting Fuel Efficiency
2.3. Other Regulatory Programs
2.3.1 Other Programs Directly Regulating MHDV Fuel Efficiency and GHG Emissions
2.3.2 Other Regulatory Programs That Indirectly Affect Fuel Consumption and GHG Emissions
3 Certification, Compliance, and Enforcement
3.2. Summary of Certification Approaches in Phase I And Phase II Rules
3.2.1 Heavy-Duty Combination Tractors
3.4. In-Use Compliance and Enforcement
3.4.1 Need for In-Use Compliance and Enforcement
3.4.2 Approaches to Determine In-Use Compliance for MHDVs
3.4.4 Individual Vehicle Compliance
4.2. Market Trends in Engine Use
4.4. Compression-Ignition-Dominated Engines
4.5. Kinetics-Dominated Combustion Engines
4.6. Natural Gas Engine Update
4.6.1 Comparing Diesel and Natural Gas Engines for Reduced NOx and GHG
4.6.2 High-Pressure Direct-Injection Natural Gas Engines
4.7. Alternative-Configuration Engines
4.8.2 Application of Waste Heat Recovery in SuperTruck and 21st Century Truck Partnership
4.8.3 Continued Development of Organic Rankine Cycle
4.9. Fuel Trends, GHG Impacts, and Infrastructure
4.9.2 Trends and Impacts from Petroleum Diesel Fuel Properties
4.9.3 Biomass-Derived Diesel Fuels
4.9.4 Trends and Impacts from Gasoline Fuel Properties
4.10. Transmission and Drivelines
5 Technologies for Reducing the Power Demand of MHDVs
5.1.1 Base Case for Over-the-Road Tractor-Trailer, Circa 2013 Specifications
5.1.2 Multiplicative Effect of Vehicle Power Demand Reduction on Engine Fuel Consumption
5.1.3 Vehicle Power Demand Reduction Goals Established by 21CTP
5.1.5 21CTP Goal’s Relation to U.S. Phase II Rule on GHGs and Fuel Consumption
5.2. Aerodynamic Drag Reduction
5.2.1 Baseline Aerodynamic Drag (CdA)
5.2.3 Aerodynamics Information from SuperTruck
5.2.4 Expect Continuing Advancements in Aerodynamics and Computational Fluid Dynamics Methods
5.3. Tires and Rolling Resistance
5.3.1 Introduction and Overview
5.3.4 Next-Generation Wide-Based Single Tires
5.3.5 Alternative Methods to Reduce Rolling Resistance
5.4.1 General Weight Characteristics of Medium and Heavy Vehicles
5.4.2 Impacts of Vehicle Mass on Freight Efficiency
5.4.3 Weight Impact in Hybrid Powertrain Vehicles
5.4.4 Cost Effectiveness of Weight Reduction
5.5. Axle and Drivetrain Losses
5.6.3 SuperTruck Projects’ Development Work on Auxiliaries and Accessories
5.7. Annex: Description of Available SmartWay-Certified Trailer Packages
5.8. Annex: Summary of SuperTruck Projects
5.8.1 Cummins-Peterbilt Project
6 Projected Benefits of Technologies on Fuel Consumption
6.1. Impact of Engine Technologies on Vehicle Fuel Consumption
6.1.2 Description of Vehicles Simulated and Results
6.2. Impact of Mass or Payload on Fuel Consumption Benefits of Different Engines
6.3. Discussion of Engine Efficiencies over Drive Cycles
6.4. Outlook for Combinations of Engine and Vehicle Improvements
7 Hybrid and Electric Powertrain Technologies
7.1.1 Hybrid Powertrains and Uses
7.1.2 Hybrid Vehicle Architectures
7.2. Differences Between Light-Duty and Heavy-Duty Hybrids
7.3. Mapping Technologies to Duty Cycles
7.4. Current Manufacturers and Product Ranges
7.6. Cost and Effectiveness of Hybrid and Electric Medium- and Heavy-Duty Vehicles
8 Battery Technology for Medium- and Heavy-Duty Hybrid and Electric Vehicles
8.1.1 Evolution of Automotive Battery Chemistries
8.1.2 Breadth of Battery Systems Offered in Light-Duty Hybrid Vehicles
8.1.3 Basic Working Principles of Li-Ion and Other Battery Chemistries
8.2. Comparison of Different Lithium Battery Chemistries, Performance, and Applications
8.2.1 Li-Ion Battery Physical Characteristics
8.2.2 Commonly Used Terms Important in Battery Assessment
8.2.3 Battery Pack Design Considerations
8.3. Influence of Medium- and Heavy-Duty Usage on Battery Performance
9 Freight Operational Efficiency
9.1. Methods to Improve Movement of Freight
9.2. Methods to Reduce Deadheading
9.3. Methods to Improve Driver-Vehicle Interaction
9.4. Countervailing Forces to Fuel Consumption Reduction
9.5.1 Truck-Rail Intermodal Transport
9.5.2 Truck-Truck Intermodal Transport
9.5.3 Inland Waterway Transport
9.6. Size and Weight Changes (Vehicle-Miles-Traveled Reduction)
9.6.1 International Comparison
9.6.2 Longer Combination Vehicles
9.7. Societal Value of Freight Efficiency Improvement
10 Intelligent Transportation Systems and Automation
10.2. Truck Parking Technology
10.4. Connected Vehicles/Cooperative-Intelligent Transportation Systems
10.5. Safety-Improving Technologies
11 Manufacturing Considerations
11.2. Advanced Manufacturing Technologies Considered
12.1. Estimates of Costs and Benefits
12.1.2 Agency Estimates of Costs and Benefits
12.1.4 Identifying the Marginal Cost of Fuel Efficiency in 2027: Vocational Segments
12.1.5 Estimating the Marginal Cost of Fuel Efficiency Improvements
12.2. The Benefits of Reduced CO2 Emissions
12.3. National Security Externalities
12.3.2 The Oil Security Premium
12.3.3 Estimates of the Security Premium
12.4. Projecting Total Capital Costs
12.4.1 Indirect Cost Estimation
12.4.4 Learning Effects on Capital Costs
13 Alternative and Complementary Regulatory Approaches
13.1. Introduction: Why Consider Alternative Approaches
13.2. Some General Principles for Regulation
13.3.1 Narrow (Selective) Regulation
13.3.4 Other Unintended Consequences
13.6. Complementary Regulations
13.6.1 Renewable Fuel Standard/Low Carbon Fuel Standard
13.6.2 Other Complementary Regulations
B Disclosure of Conflicts of Interest
D Summary of Analysis of Engine and Vehicle Combinations
E Description of Drive Cycles Used for Compliance
