### I nter n ati o na l Co u ncil o n Clean T:-ansportation Testi mony on P rop o sed Ph ase 2 G reenhou se Gas Emi ss ions Sta nd ards and Fu e l Eff ic ie n cy Standard s f or Me dium - a nd Heavy- Duty Engine s and Ve hi c les · 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 ve h icle 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 i n a country's vehicle efficien cy without efficiency regulations , even though efficiency technology 

### surely has come a long way. T his regulation would solve such problems . Regarding the agencies ' an a lysis on availabl e efficiency t e chnologies , 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 publ ic 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 resea rch studies, I will make brief remarks on the 

# - timing 

### of the techno logy 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 tech nologies 3• 4

. 

### T he techno logies i n the engine, powertrai n , aerodynamics , and tire areas are exactly the ones that suppliers and vehicle manufacturers have been discussing for
1 V ernon and Meier, 2012. Identification and quan t ifica ti on ofprincipal-agent problems affect ing 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 ofadvanced 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 ofintegrating trailers into heavy-duty vehicle efftciency regulation . http: li

www .theicct .orglintegrating-trailers- hdv-regulation-benefit-cost-analysis. July.th e rules ' timeframe 5

. The trailer technolog i es embrace the emerging technologies that have already been spurred by EPA 's SmartWay program and California's in-use regulation 6
. Due to the agen cies ' 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 technolog i es 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 20 1 7 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 literature 7
·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 leade r 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. orgls t akeholder-•mrkshop-report·t lactor -tratler-elf,ctency-rechnology-20 15- 2030. 5 Sharpe and Roeth (2014). Costs and adoption rates offuel-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 t ractor- trail er efficiency technologypotential in the 2020-2030 timeframe. hl/p 11\'\\ 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,'cafe 1Dialt-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'e 1 t ment-advanced-hdl efftc•enq IL'Chnologtes. 1 1 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. airpollution, 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 Tr a nsportPoltcy . net ( 2015 ). Global Compar i son: Heavy-duty Fuel Economy and GHG. • ,,, •• I\ • r <; )._ I, • '\ nt! h ) php"llll =G. •t a CompatrS If Heal}. ill Ft t Economy a nd GHG 2

### the rules' timeframe 5

. 

### The trailer technologies embrace the eme rging technologies that have already been spurred by EPA's SmartWay program and California's in-use regulation 6

. 

### 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 techno logies 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 diese l tractor engine fuel use fleet-wide by up to 10% from 2017 to. 2027, based on our own technical analysis and the research literature 7•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 adopt ion rates offuel-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 . T hiruvengadam eta/ (2014) Heavy-duty vehicle diesel engine efficiency evalua tion 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 Lu t sey (2015) . Advanced tractor-trailer efficiency technologypotential in the 2020-20 3 0 timef r ame. 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

**Luts ey**  (2014). The U.S. SuperTruck Program: Exped iting development ofadvanced 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\ -e tftCiencyrecnnoiOgleS. 1 1 Lutsey (20 15). Regulatory considerations for advancing commercial pickup and van efficiency technolog y 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. alfpolluiion. 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