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Medium duty vehicles come in many design variations, which makes testing them all for CO2 impractical. As a result there are multiple ways of reporting CO2 emissions. Actual tests may be performed, data substitution may be used, or CO2 values may be estimated using an analytical correction. The correction accounts for variations in road load force coefficients (f0, f1, f2), weight, and axle ratio. The EPA Analytically Derived CO2 equation (EPA ADC) was defined using a limited set of historical data. The prediction error is shown to be ±130 g/mile and the sensitivities to design variables are found to be incorrect. Since the absolute CO2 is between 500 and 1,000 g/mi, the equation has limited usefulness. Previous work on light duty vehicles has demonstrated a linear relationship between vehicle fuel consumption, powertrain properties and total vehicle work. This relationship improves the accuracy and avoids co-linearity and non-orthogonality of the input variables.