EPA underestimated compliance costs by a factor of 2 to 5, according to ATD analysis. ATD calculated actual truck compliance costs based on individual sales invoices and OEM sales documents. Many invoices contained specific cost line items—surcharges or escalators—that specified cost increases attributable to the new emission standards.
For 2010 emission compliance for heavy heavy-duty trucks, the actual surcharges by different manufacturers varied from $7,736 to $9,600, compared to an amount of $3,419 predicted by the EPA
The cumulative surcharges for 2004 through 2010 emission compliance in heavy heavy-duty trucks by Freightliner, Volvo and Western Star were $21,440, $21,471 and $21,876, respectively, while the EPA predicted a cost increase of $5,136.