International Council on Clean T:-ansportation Testimony on Proposed Phase 2 

Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and 

Heavy-Duty Engines and Vehicles · 

August6, 2015 

Chicago, Illinois 

Good morning. Thank you for the opportunity to provide remarks on this very important 

rulemaking. 

I'm Nic Lutsey, with the International Council on Clean Transportation. We are a research 

organization that is focused on providing technical information to support government 

decision-making on policies, like these Phase 2 regulations, for leading vehicle markets 

around the globe. I'll make brief comments for the ICCT about market conditions, technical 

aspects, and international implications related to the proposed rules. 

First, market conditions in the US freight trucking industry are preventing the uptake of 

available cost-effective efficiency technologies. There are substantial market barriers that 

impede the uptake of efficiency technology 1

·

2

• Among the barriers are (1) the disconnect 

between who purchases the technology and who receives the fuel-saving benefit; (2) the 

limited data available to truck owners on technologies' real-world benefits; and (3) limited 

availability of technology. In our global work on vehicle efficiency, we have found no evidence 

of a sustained fleet-wide increases in a country's vehicle efficiency without efficiency 

regulations, even though efficiency technology surely has come a long way. This regulation 

would solve such problems. 

Regarding the agencies' analysis on available efficiency technologies, we continue to be 

very grateful for the extensive information sharing and dedicated time from EPA and NHTSA 

staff. The agencies' work ethic, transparency, and public process are exemplary. The 

agencies have undoubtedly made a rule based on rigorous, state-of-the-art technology inputs 

from sound data and industry input. 

Based on several new technicai iCCT research studies, I will make brief remarks on the 

timing of the technology deployment, as well as on 

-full technology potential, especially in the 

engine area. In the agencies' analysis, the rule is predicated on well-understood, highly costeffective technologies3

•

4

. The technologies in the engine, powertrain, aerodynamics, and tire 

areas are exactly the ones that suppliers and vehicle manufacturers have been discussing for 

1 Vernon and Meier, 2012. Identification and quantification of principal-agent problems affecting energy efficiency 

investments and use decisions in the trucking industry. Energy Policy. 

!!lip ll\1 ~ ence1 •comscr~1CPa'tiC ~ S030t.J2151200523>. 7 Roeth eta/ (2013). Barriers to the increased adoption of fuel efficiency technologies in the Nor1h American on-road 

freight sector. http ,'1\'\H\.thetcct.otg hdl•·technology-markot bamers-north·america. 3 Meszler eta/ (2015). Cost effectiveness of advanced efficiency technologies for long-haul tractor-trailers in the 202G2030 timeframe. http 111\ ,\ thetcct c '9 •us-t • ell" t atler·terl ·cos•·eifeclllt u•ss. 

Sharpe et al (2014). Benefit-cost analysis of integrating trailers into heavy-duty vehicle efftciency regulation. 

http:liwww. theicct. orglintegrating-trailers-hdv-regulation-benefit-cost-analysis. July. 
the rules ' timeframe5

. The trailer technologies embrace the emerging technologies that have 

already been spurred by EPA's SmartWay program and California's in-use regulation6

. Due 

to the agencies' decisions to rely on proven, available, and cost-effective technology choices, 

the agencies can shift the standards 3 years earlier- from 2027 as proposed, forward to 

2024. This would still allow sufficient lead-time for the manufacturers and truck buyers to 

gradually incorporate all the technologies into their operations over the next nine years. 

We have noticed several areas where the agencies do not fully incorporate available 

technologies. One area is in engines, where the agencies proposed to reduce the tractor 

diesel engine fuel use by 4% from 2017 to 2027. Available technologies with payback periods 

comfortably less than 2 years can reduce new diesel tractor engine fuel use fleet-wide by up 

to 1 0% from 2017 to 2027, based on our own technical analysis and the research 

literature7

·

9

·

9

. With higher technology penetration rates for US DOE SuperTruck technologies, 

the standards could go further yet 10. In addition, the proposed heavy-duty pickup and van, as 

well as gasoline efficiency, standards appear to fall significantly short in their promotion of the 

full technology potential 11 . -

Finally, this rulemaking is key in establishing the US as a global leader on freight truck 

efficiency. The governments of Canada, China, Europe, India, Japan, Mexico, and others are 

also considering their next policy actions to similarly ensure greater efficiency technology 

deployment for trucks 12

•

13•

14

• The world is watching, and potentially looking to adopt, similar 

policy. 

We provide links to the leading technical research that supports these statements, and we 

will, of course, elaborate on the points in our detailed comments to the docket. 

Again, we thank the agencies for their exemplary public service. 

5 Lutsey et al (2014). Stakeholder workshop report on tractor-trailer efficiency technology m the 2015-2030 timeframe. 

tp:l;ww• . t11e1CCI. orglstakeholder-•mrkshop-report·tl actor-tratler-elf,ctency-rechnology-20 15-2030. 5 Sharpe and Roeth (2014). Costs and adoption rates of fuel-saving technologies for trailers in the North American onroad freight sector. hllp \\ ~~ '' the•cct org costs-and-adoptton-rates-fuel-savmg-trailer-technolog,es. February. 7 Thiruvengadam eta/ (2014) Heavy-duty vehicle diesel engine efficiency evaluation and energy audtt. 

11/lp:llwww tlletcct orgtt1eavy-duty vehtcle·dtesel-engmeefftctency-evaluation-and-energy-audit. 8 Delgado and Lutsey (2015). Advanced tractor-trailer efficiency technology potential in the 2020-2030 time frame. 

hl/p 1

1\'\\ 1\ the,cct org~us tractor-tratler efftcft•ncy technology. 

9 Reinhart (2015). Commercial Medium- and Heavy-Duty Truck Fuel Efficiency Technology Study- Report #2. Draft. 

http.llwww nhtsa go• stattcftlestwfemakinglpdf,'cafe1

Dialt-SwRI-MDHD-FE-TechRepor/2 DocketVerston pdf 10 Delgado and Lutsey (2014). The U.S. SuperTruck Program: Expediting development of advanced HDV efficiency 

technologies. http ,. >I 11 the,cct o Jus-sup rt·uck-prc:;'·"~m expe iltong-del'e1 t ment-advanced-hdl efftc•enq 

IL'Chnologtes. 11 Lutsey (2015). Regulatory considerations for advancing commercial pickup and van efficiency technology in the 

United States. http ww1\ rhetcct org'tJS·commetctal-ptckups-vans efftctency-tecl'mology. 

t? Sharpe (2015). Testing methods for heavy-duty vehicle fuel efficiency: Trends and imp/tea/ions for India. 

nt•, the•cct <. ·g Sttes a• raul(lltles pub/teat· :111. ICCT HDl -test-pr· <:c..dures lnt/ie 20 t504.c!O.paf 13 Kodjak (2015). Policies to reduce fuel consumption. air pollution, and carbon emissions from vehicles in G20 nations. 

hllf' tht 1CC/ (lrg poltCu.;•s-reL1UCt fuel-consump/lon-au-pollulton-ancl-carbon·emtsstons veh,cles-g20-nations. 14 TransportPoltcy.net (2015). Global Comparison: Heavy-duty Fuel Economy and GHG . 

• ,,, •• I\ • r <; )._ I, • '\ nt! h ) php"llll =G. •t a CompatrS If Heal}. ill Ft t Economy and GHG 

2 
the rules' timeframe5

. The trailer technologies embrace the emerging technologies that have 

already been spurred by EPA's SmartWay program and California's in-use regulation6

. Due 

to the agencies' decisions to rely on proven, available, and cost-effective technology choices, 

the agencies can shift the standards 3 years earlier- from 2027 as proposed, forward to 

2024. This would still allow sufficient lead-time for the manufacturers and truck buyers to 

gradually incorporate all the technologies into their operations over the next nine years. 

We have noticed several areas where the agencies do not fully incorporate available 

technologies. One area is in engines, where the agencies proposed to reduce the tractor 

-mesel engine fuel use by 4% from 2017 to 2027. Available technologies with payback periods 

comfortably less than 2 years can reduce new diesel tractor engine fuel use fleet-wide by up 

to 10% from 2017 to. 2027, based on our own technical analysis and the research 

literature7

•

8

·

9

. With higher technology penetration rates for US DOE SuperTruck technologies, 

the standards could go further yee0

. In addition, the proposed heavy-duty pickup and van, as 

well as gasoline efficiency, standards appear to fall significantly short in their promotion of the 

full technology potential 11. -

Finally, this rulemaking is key in establishing the US as a global leader on freight truck 

efficiency. The governments of Canada, China, Europe, India, Japan, Mexico, and others are 

also considering their next policy actions to similarly ensure greater efficiency technology 

deployment for trucks '

2

•

13•

14• The world is watching, and potentially looking to adopt, similar 

policy. 

We provide links to the leading technical research that supports these statements, and we 

will, of course, elaborate on the points in our detailed comments to the docket. 

Again, we thank the agencies for their exemplary public service. 

Lutsey eta/ (2014). Stakeholder workshop report on tractor-trarler efficiency technology in the 2015·2030 timeframe. 

"'';J I• I' I' tl1e•CCi Q g. S!h e'JO der- I ~f~ShOJ · t ~ iri.:Y·I·a er-;>/IIC·enq · t?C"'1.'1010;}\ -2015 21130. 6 Sharpe and Roeth (2014). Costs and adoption rates of fuel-saving technologies for trailers m the North American on· 

road freight sector. "llfp 1'•11 11 !he•ccr org cos!s-a'ln-a..:optton-rates-1Ue,·S81'tng-rraller-techno c1q:es. February. 

Thiruvengadam eta/ (2014) Heavy-duty vehicle diesel engine efficiency evaluation and energy audit. 

!ltlp . ,.,.,., ,., t!1e1CCi org·hec11 y-outr-ven:cle·dlesel-eng:n.-,~ .'rc,ency-evalur:won-anc1·energy-au<ltl. 

8 Delgado and Lutsey (2015). Advanced tractor-trailer efficiency technology potential in the 2020-2030 timeframe. 

hllp 11'11'11 tlle•cct.org us-tracror·/larler-efflcrency-tecnnology. 

s Reinhart (2015). Commercial Medium- and Heavy-Duty Truck Fuel Efficiency Technology Study- Report #2. Draft. 

•w_ 1',11 "'>:sa co"·Sicc • ct '<"" t.lern;;Kinc pa' c •. • C •.:1 ·S:. P ·'.:OHO "'E Tee •:=lepor:._ :Jt. v .etl 'e·s or;.pcf 10 Delgado and Lutsey (2014). The U.S. SuperTruck Program: Expediting development of advanced HDV efficiency 

technologies. 'Itt;; t·. ,.,,/he ,cc; eo p us·sl oc;, c, p,,J~,ram expe 1.•r nwdel e -wnem-e:avanCPt)·'10\ -etftCiencyrecnnoiOgleS. 11 Lutsey (20 15). Regulatory considerations for advancing commercial pickup and van efficiency technology in the 

United States. I'Jilp ,n lVI'. l'lr:>ir.cr ,l,fl us-comm~·c:c~· p,r;wps·va'ls etf•c:enc~-tec'morom . 12 Sharpe (2015). Testing methods for heavy-duty vehicle fuel efficiency: Trends and implications for India . 

. t1rr:, f,S't?S:-:~d'•tuleSfJ1.1!JUCCHQ'1~ C(- "'rO\·ft~s£·~,_ ··-oceat ~ Jrul?.. 2(1 4

504.:-.U; 13 Kodjak (20 15). Policies to reduce fuel consumption. alf polluiion. and carbon emissions from vehicles in G20 nations. 

,..., - ~ •. :' • ~ £ ,.. .. ~ ~ -co.·,s.._ r •i JL t i ·1:1-r:r \.J- .(7 t' J ·! ,.... :!=s.Jns-·. :?11 c t s ~o. 20-na: ons. 

'" TransportPoticy.net (2015). Global Comparison: Heavy-duty Fuel Economy and GHG . 

•. ,.. 1t 1 · :· s~)c··;_, ..... ,(\ 'I• 1 ·h·t: ;.;r:;...,~'lt!h-.:.. .. --;·, •1 L~C't,.lD:tqs:Jn He--t•. v-r:r~.i'\ ;.ue. =cn.'1otn\ CJ'?n GHG 

2