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3 HEAVY-DUTY GREENHOUSE GAS AND FUEL EFFICIENCY 

4 STANDARDS: PHASE 2 PROGRAM HEARING 

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7 Thursday, August 6, 2015 

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20 Palmer House Hilton Hotel 

21 17 East Monroe Street 

22 Chicago, Illinois 60603 
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1 CHRISTOPHER GRUNDLER, Co-Presiding Officer, EPA 

2 JAMES TAMM, Co-Presiding Officer, NHTSA 

3 GORDON TROWBRIDGE, NHTSA 

4 ANALIESE MARCHESSEAULT, NHTSA 

5 JESSICA BRAKORA, EPA 

6 STEVEN SILVERMAN, EPA 

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1 P R O C E E D I N G S 

2 MR. GRUNDLER: Good morning, everybody. My name 

3 is Chris Grundler. I'm the director of EPA's Office of 

4 Transportation and Air Quality. I'm here with my 

5 colleague, Jim Tamm, from the Department of 

6 Transportation's National Highway Traffic Safety 

7 Administration. Jim and I will be presiding over 

8 today's proceedings. 

9 First, let me welcome everyone here to Chicago as 

10 well as everyone listening by the phone. I'm very 

11 pleased to see the turnout today where we had over 70 

12 people from a lot of organizations registered to speak 

13 today. To me, this is one of my highest 

14 responsibilities, hearing directly from people on the 

15 impacts of decisions that their government may be 

16 making. So this is an honor for me to be here, and I 

17 really am grateful for people taking the time to come 

18 here and express their views. We are listening. 

19 On July 13th, EPA and NHTSA proposed the second 

20 phase of our joint program to regulate the greenhouse 

21 gas emissions and fuel efficiency of heavy duty engines 

22 and vehicles. This proposal, which we have issued 
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1 under Clean Air Act and Energy Independence and 

2 Security Act authorities, is an important part of the 

3 President's climate action plan to address the 

4 challenges of global climate change and energy 

5 security. 

6 For well over two years now, our agencies in 

7 conjunction with our colleagues in California have 

8 conducted an extensive testing and research effort, and 

9 have worked with industry and other States and other 

10 stakeholders to develop these ambitious, yet 

11 achievable, standards that encourage deployment of 

12 advanced and cost-effective technologies to reduce both 

13 fuel consumption and greenhouse gas emissions. 

14 We believe this proposal represents an opportunity 

15 to spur innovation in the clean energy technology 

16 marketplace, creating opportunities for job growth and 

17 promoting a new generation of cleaner, more efficient 

18 trucks. 

19 The environmental and economic benefits of our

20 proposal are substantial. The standards as proposed 

21 would cut greenhouse gas emissions by a billion metric 

22 tons, conserve up to 1.8 billion barrels of oil, and 
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1 save vehicle owners fuel costs of about $170 billion 

2 over the lifetime of the vehicles sold. Payback 

3 periods for truck owners would be favorable. The buyer 

4 of a new long haul truck in 2027 would recoup the extra 

5 cost of the technology in under two years through fuel 

6 savings. 

7 EPA and NHTSA have worked to ensure that the 

8 standards are harmonized between NHTSA and EPA. The 

9 agencies have also worked very closely with the State 

10 of California's Air Resources Board in developing these 

11 standards, and all three agencies are committed to the 

12 goal of setting a single set of national standards.

13 The second phase of our program is designed to

14 allow manufacturers to continue to build a national

15 fleet of heavy duty vehicles that satisfy all 

16 requirements under EPA and NHTSA's respective programs, 

17 and would help to address the greenhouse gas reduction 

18 goals of California and other states well into the next 

19 decade. Although we have put a great deal of work into 

20 our proposal, these Phase 2 proposed standards are just 

21 that. They are proposed standards. We welcome 

22 feedback from stakeholders and the public to help us 
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1 craft a final program that will achieve significant

2 fuel savings in greenhouse gas emission reductions 

3 while ensuring the heavy duty industry will continue to 

4 meet the diverse need of our transportation sector 

5 Today's hearing is being held to allow interested 

6 parties to provide us with comments on this proposal in 

7 person. On August 18th, we'll hold a second public

8 hearing in Long Beach, California. There's also an

9 opportunity for everyone to send us written comments. 

10 The comment period will close September 17th. 

11 Instructions for submitting written comments are 

12 provided on our website, and copies of those 

13 instructions are available outside at the registration 

14 table. The agencies expect to take final action on

15 this proposal some time next spring. 

16 Now, let me introduce our other panel members 

17 sitting with me and then outline how today's hearing is 

18 going to be conducted. Representing EPA with me on our 

19 panel today is Jessica Brakora from our office. Steve 

20 Silverman is on my left from our Office of General 

21 Counsel. He's no doubt somewhere between here and 

22 O'Hare. I already introduced Jim. He's the chief of 
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1 the Fuel Economy Division at NHTSA. Gordon Trowbridge 

2 is the director of communications on the far end, and 

3 next to him is Analiese Marchesseault from the Office 

4 of Chief Counsel of NHTSA. 

5 This hearing will be conducted informally, and

6 formal rules of evidence will not apply. The presiding 

7 officers, however, are authorized to strike statements 

8 from the records that are deemed irrelevant or 

9 needlessly repetitious, and to enforce reasonable 

10 limits on the duration of the statement of any witness. 

11 We will have helpful lights to remind you when your 

12 time will be up. 

13 We're scheduled to run until about 5:00 or 6:00 

14 p.m., but we will be here as long as it takes to allow 

15 everyone to have their say that wants to. We'll be

16 using panels to speed up the process and reduce the

17 transaction time. The list of pre-registered panel

18 members and their order is provided with the agenda at 

19 the reception table. We ask that each person keep 

20 their testimony to five minutes or less. If anyone

21 here wishing to testify has not already signed up, 

22 please do so. And whether you're testifying or not, 
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1 we'd be grateful if you signed the regulation sign up 

2 list. 

3 When all the witnesses on a panel have finished, 

4 those of us on the government panel will have an 

5 opportunity to ask questions. We plan to go through 

6 the first five panels before breaking for lunch and

7 then begin the afternoon session at 1:30. After today, 

8 if any of you wishes to make any corrections to your 

9 remarks, please submit those corrections to EPA or 

10 NHTSA within 30 days. If you'd like a transcript of 

11 today's proceedings, please make arrangements directly 

12 with the court reporter sitting here in the middle 

13 during one of the breaks. 

14 I have one final announcement before turning it 

15 over to my NHTSA colleague. EPA would like to provide 

16 additional notice regarding a proposed change to the 

17 engine testing regulations found at 40 CFR 1036.501(g). 

18 This amendment would require the exclusion of any work 

19 performed by the engine during any idle portion of the 

20 duty cycle when calculating total engine work. This 

21 proposed change was included in the proposed regulatory 

22 text, but not highlighted in the preamble to the Phase 
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1 2 Notice of Proposed Rulemaking. 

2 This change has the potential to impact the 

3 effective stringency of the engine standards. For 

4 gasoline engines, this means that the effective 

5 stringency could increase without a change to the 

6 numerical stringency of the standards. So to ensure 

7 that commenters have adequate opportunity to comment on 

8 this issue, we are placing into the docket for this

9 rulemaking a memorandum providing additional detail on 

10 this proposed change. Commenters interested in the

11 gasoline engine standards are encouraged to read this 

12 memorandum and provide comments on this change, along 

13 with any other comments on the proposed rule. 

14 So at this time I’d like to turn it to over to Jim 

15 to give his introductory remarks. Jim? 

16 MR. TAMM: Thank you, Chris, and good morning to 

17 everybody. On behalf of the National Highway Traffic 

18 Safety Administration and the Department of 

19 Transportation, I’d like to thank you for taking time 

20 out of your busy schedule to come here and to provide 

21 comments on our proposed fuel efficiency and greenhouse 

22 gas emission regulations. 
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1 NHTSA and the Department of Transportation were 

2 proud to work with our partners at EPA to develop a

3 joint proposal for the second phase of the greenhouse 

4 gas and fuel efficiency standards. Our goal is to 

5 build on the successful Phase 1 standards for vehicle 

6 model years 2014 through 2018. The proposed Phase 2 

7 standards would cover model years 2021 to 2027 and 

8 beyond and apply to semi-trucks, large pickup trucks 

9 and vans, and all types and sizes of buses and work

10 trucks. For the first time standards would apply to 

11 most heavy duty trailers. Trailer standards would 

12 start in model year 2018. 

13 The agencies are committed to the goal of setting 

14 a single set of national standards that are cost 

15 effective for consumers and businesses and deliverable 

16 -- deliver a favorable payback period to truck owners. 

17 EPA and NHTSA jointly issued several documents

18 related to the Notice of Proposed Rulemaking. They

19 include a preamble and a regulatory impact analysis. 

20 These documents describe the proposed regulations and 

21 provides supporting information and the analysis 

22 related to the proposal. 
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1 In addition on June 19, NHTSA published a draft 

2 environmental impact statement for the proposed NHTSA 

3 fuel efficiency regulations. The draft environmental 

4 impact statement compares the environmental impacts of 

5 the proposed fuel efficiency regulations with those of 

6 a number of alternatives. In today's hearing, we 

7 provide opportunity for the public to comment on both 

8 the Notice of Proposed Rulemaking documents and NHTSA's 

9 draft environmental impact statement. 

10 Please note that while the comment period for 

11 Notice of Proposed Rulemaking closes on September 17, 

12 the comment period for the draft environmental impact 

13 statement will close on August 31st. Our two Agencies 

14 welcome feedback from stakeholders and the public to 

15 help us best craft a final program for the country. 

16 Your input is important to us, and we look forward to 

17 hearing what you have to say. 

18 So before we bring up the first panel, I’d like to 

19 ask each panelist to please when you do come up front, 

20 please state your name and affiliation, and to speak 

21 slowly and clearly so our court reporter can record

22 these proceedings accurately. 
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1 And this time, I think we're ready to bring up the 

2 first panel. And as Chris noted, to assist in keeping 

3 the testimonies on track, we do have a series of 

4 lights. Just for the speakers, you'll receive a green 

5 light up until one minute. I'm sorry. There are five 

6 minutes that we're targeting for each speaker. For the 

7 first four minutes, the green light will be on. The 

8 yellow light comes on one minute is remaining, and then 

9 the red light will come on at five minutes. Also, 

10 we're going to have the panelists up here at the main 

11 table, but we've also arranged for a staging area, 

12 which are the chairs back there, and JoNell is waving 

13 back there. So we're going to call up the first panel, 

14 and we would ask that panel to come up to the main 

15 table, and then also call a second panel and ask them 

16 to go to the staging area, please. 

17 So our first panel would be Jed Mandel, Nick 

18 Lutsey, Kenneth McAlinden, Jason Mathers, Chris Hess, 

19 and Luke Tonachel. So if you all come to the -- thank 

20 you -- main table. And then the panel two, if you 

21 could come over to the staging area: Siddiq Khan, Gary 

22 Oshnock, Kelly Nichols, Eric Jorgensen, Chuck Frank, 
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1 and David Cooke. I think we'll wait a moment until

2 everybody has a chance to be seated, and then we'll get 

3 started. 

4 Mr. Mandel, you may proceed. 

5 MR. MANDEL: Thank you. Good morning. I'm Jed 

6 Mandel. I'm president of the Truck and Engine 

7 Manufacturers Association. EMA's members manufacture 

8 the medium and heavy duty engines in vehicles that are 

9 the subject of today's rules. As you know, EMA members 

10 are instrumental in working with EPA, NHTSA, our 

11 customers, and other stakeholders on EPA's and NHTSA's 

12 historic Phase 1 rule. 

13 That rule was a success for, among other reasons, 

14 because the final rule was structured around certain 

15 key principles: adopting a single nationwide GHG FE 

16 program, increasing the utilization of existing 

17 technologies to achieve substantial time gains, 

18 recognizing the commercial needs of the marketplace and 

19 the complexity of product offerings, and avoiding 

20 unintended consequences. 

21 EMA and its members have advocated that similar 

22 principles guide the development and implementation of 
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1 Phase 2. Given EPA's and NHTSA's stated intent to 

2 adopt a significantly more stringent program, one that 

3 forces the development of technology, an appropriate -- 

4 the appropriate and necessary principles are somewhat 

5 modified. However, it remains absolutely critical that 

6 we maintain a single nationwide program. That not only 

7 means that the EPA and NHTSA rules must align, but that 

8 California must fully harmonize as well. 

9 In that regard, we are aware that California has 

10 advocated that EPA consider adopting a more aggressive 

11 timeline for the Phase 2 standards, along with lower 

12 NOx if contemporaneous with the proposed Phase 2 

13 standards. More important, California has indicated 

14 they will consider adopting more stringent GHG and NOx 

15 limits on their own if EPA does not act. 

16 We have an almost 30-year history of alignment

17 between carbon and EPA heavy duty emissions standards. 

18 That alignment is a fundamental cornerstone to the

19 cost effectiveness and implementability of the world's 

20 most stringent criteria emissions control program. 

21 Full regulatory alignment was similarly critical to the 

22 success of Phase 1. Fifty-state harmonization likewise 
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1 is absolutely critical to the feasibility of Phase 2. 

2 Given the well-known, well-documented physics 

3 associated with the tradeoff between NOx emissions and 

4 greenhouse gas fuel efficiency limits, it's not enough 

5 that California aligns itself with EPA's greenhouse gas 

6 limits, including on the same timeline recommended and 

7 established by EPA. CARB also must continue to fully 

8 align with EPA and NOxemissions as well. To do 

9 otherwise would seriously jeopardize the success of

10 both the greenhouse gas fuel efficiency rule and EPA's 

11 Criteria Emissions Control Program. 

12 We've remained open to hearing from both CARB and 

13 EPA on their interest in exploring possible future 

14 lower NOx reductions, and how and when they can be 

15 achieved. But in the meantime, a nationwide fully 

16 harmonized GHG criteria emission program must be 

17 maintained. It also is essential that the final rule 

18 recognizes the commercial needs of the marketplace and 

19 the complexity of product offerings, and avoids 

20 unintended consequences. To that end, the final rule 

21 must provide adequate lead time and stability, balance 

22 stringency costs and implementation dates, look to 
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1 improve in opportunities beyond just those that are in 

2 the control of truck and engine manufacturers, account 

3 for the impacts of trailer design on tractor 

4 aerodynamics, and assure uniform, accurate, cost5 effective, and reliable simulation modeling and 

6 measurement methods. 

7 The proposed rule and accompanying draft 

8 regulatory impact analysis are incredibly complex. 

9 They envision a strong, aggressive Phase 2 -- program 

10 of Phase 2 GHG reductions and fuel improvements. The 

11 proposal also demonstrates that the agencies can 

12 consider multiple options, are open to potential 

13 changes before the rule is finished, and are committed 

14 to work with all stakeholders to finalize a rule that 

15 substantially reduces greenhouse gas emissions and 

16 improves fuel efficiency in a way that is cost 

17 effective and implementable, would be accepted by 

18 customers, and will provide real world improvements. 

19 While those rules are envisioned in the proposal, 

20 they are not yet fully integrated into the proposed

21 regulations. In all candor, we still are stuck in the 

22 details of today's massive proposal. We're focused on 
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1 making sure that the final rule gets it right. To 

2 achieve that goal, we have committed to continuing to 

3 work with EPA and NHTSA to ensure that a strong, 

4 effective, and implementable rule is finalized, when it 

5 needs the principles that we long have articulated, and 

6 that we believe EPA and NHTSA support. 

7 Today is not the time and place for us to 

8 delineate with specificity all of our areas of concern, 

9 but I'll take a moment to identify a few key concerns. 

10 We know that today's ruling includes a number of 

11 proposals that would change the Phase 1 rule. 

12 Manufacturers already have fully committed to their

13 project development plans for Phase 1 compliance. EPA 

14 and NHTSA must not either create uncertainty or 

15 eliminate essential regulatory stability by attempting 

16 to make retroactive changes to the Phase 1 rule. 

17 As you know, under the Department of Energy's 

18 Super Truck Initiative, EMA members have developed 

19 prototype engine, tractor, and trailer combinations

20 that achieved innovative, game-changing improvements in 

21 freight efficiency. Yet based on our preliminary 

22 assessments, even those super trucks, which include
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1 technologies and design elements that exceeded what

2 would be commercially viable in 2027, wouldn't be 

3 capable of achieving the best-performing vehicle 

4 requirements contemplated by the proposed rule. We

5 don't believe that EPA's and NHTSA's intent is to adopt 

6 rules that require the development of new technologies 

7 beyond the super truck prototypes just now being 

8 developed as the reference for compliance with Phase 2. 

9 Accordingly, we believe that it is necessary to find 

10 the reference assumptions and create many of the 

11 underlying assumptions about technology penetration

12 rates for certain market segments in order to finalize 

13 a technologically feasible and implementable rule. 

14 EPA and the NHTSA also are proposing significantly 

15 more robust and complex simulation models. With those 

16 new models, significant test variability associated

17 with measurement accuracy, varying ambient conditions, 

18 test truck differences, tractor variability, and 

19 multiple trailer gap and trailer configurations. We 

20 believe the agencies can and must minimize the many

21 components that contribute to that variability. Where 

22 they cannot fully do so, it is incumbent on the 
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1 agencies to provide some degree of testing margin to 

2 account for that variability. Otherwise, to ensure

3 technical compliance, manufacturers will be forced to 

4 downgrade the actual real world greenhouse gas fuel

5 efficiency performance of their tractors. 

6 However, the net result of being forced to do so 

7 will be their inability to achieve the certification 

8 levels contemplated by the proposed rule. 

9 Consequently, the agencies' allowance of sufficient

10 test and audit margins are key to the implementation of 

11 feasible technology forcing Phase 2 standards. 

12 MR. GRUNDLER: Can you wrap it up, please? 

13 MR. MANDEL: Yeah. I'm going to read my last two 

14 paragraphs only because you're avoiding having all of 

15 the EMA's members testifying today by having the chance 

16 to hear my lovely voice for another minute. And so

17 with your forbearance, I'm going to just finish my 

18 statement if that's all right. 

19 MR. GRUNDLER: As long as Nick yields the balance 

20 of his time. 

21 MR. MANDEL: Exactly. We know that EPA and NHTSA 

22 are attempting to find a balance between separate 
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1 engine and complete vehicle standards. Our members

2 have strong views on that subject. You have heard from 

3 them and will continue to hear from them. However, as 

4 an industry we are agreed that it is critical that the 

5 agencies get right the intersect between those two 

6 views, specifically the manner in which the engine is 

7 accounted for in GEM. 

8 As it stands now, the agencies have not yet got it 

9 right. Among other things, in attempting to connect 

10 the engine and vehicles standards, EPA and NHTSA have 

11 yet to account for the known variability associated

12 with measuring the fuel consumption of an engine and to 

13 simulate that engine in GEM. The compliance margin is 

14 absolutely necessary, especially in the context of an 

15 agency audit to account for inherent variability and 

16 characterizing energy fuel consumption. Without that 

17 compliance margin, the proposed rule will not be 

18 feasible. 

19 As with Phase 1, EMA members are committed to 

20 working with EPA and NHTSA to resolve the many 

21 important open issues, including those I've touched on 

22 today. We're providing our best technical assessment 
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1 of the proposed rule and our recommendations for 

2 necessary improvements, all supported by data. Our

3 customers have long demanded fuel efficiency. We have 

4 worked to continuously improve it, even while making 

5 incredible improvements in the reduction of criteria 

6 pollutants. We intend to continue to provide improved 

7 fuel efficiency and the corresponding improvements in 

8 GHG emissions. 

9 To that end, it is essential that the final rule 

10 provide an appropriate, fair, cost effective, and 

11 implementable regulatory framework for those future

12 improvements, one that does not disrupt the market or 

13 cause serious unintended consequences. We are ready to 

14 assist in that effort. If you have questions, I’d be 

15 happy to answer them, and I appreciate your giving me 

16 the latitude of an extra minute or two. 

17 MR. GRUNDLER: Don't let Mr. Mandel be a model for 

18 the rest of rest of the testifiers today. 

19 (Laughter.) 

20 MR. GRUNDLER: Mr. Lutsey. 

21 MR. LUTSEY: Fair enough. Good morning. Thank 

22 you for the opportunity to provide remarks here on this 
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1 very important rulemaking. My name is Nick Lutsey. 

2 I'm with the International Council on Clean 

3 Transportation. We are a research organization that is 

4 focused on providing technical information to support 

5 governments in their decision-making and policies like 

6 these Phase 2 regulations in leading vehicle markets 

7 around the world. I'll make brief comments for ICCT 

8 about market conditions, technical aspects, and 

9 international implications related to the proposed 

10 rules. 

11 First, market conditions in the U.S. freight 

12 trucking industry are preventing the uptake of 

13 available cost-effective efficiency technologies. And 

14 there are substantial market that impede the uptake of 

15 efficiency technology. Among the barriers are the 

16 disconnect between who purchases the technology and who 

17 receives the fuel saving benefit in some cases, the

18 limited data available to truck owners on technologies' 

19 real world benefits, and limited availability of the 

20 technologies themselves. 

21 In our global work on vehicle efficiency, we have 

22 found no evidence of any sustained fleet-wide increase 
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1 in any countries vehicle efficiency without efficiency 

2 or CO2 regulations, even though efficiency technology 

3 surely has come a long way. This regulation would 

4 resolve such problems. Regarding the agencies' 

5 analysis of available and emerging technologies, we

6 continue to be extremely grateful for the extensive

7 information sharing and dedicated time from EPA and

8 NHTSA staff. The agencies' work ethic, transparency, 

9 and public process are exemplary. The agencies have 

10 undoubtedly made a rule based on rigorous state-of-the11 art technology inputs, and sound data and industry 

12 input. 

13 Based on several new ICCT research studies, I will 

14 make brief remarks on the timing of technology 

15 deployment well as the full technology potential, 

16 especially in the engine area. 

17 The agencies' -- in the agencies' analysis, the 

18 rule is largely predicated upon well-understood, 

19 highly-cost effective technologies. The technologies 

20 in the engine, transmission, aerodynamics, and tire

21 areas are exactly the ones that suppliers and vehicle 

22 manufacturers have been discussing for the rule's 
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1 timeframe. The trailer technologies embrace the 

2 emerging technologies that have already been spurred by 

3 EPA's SmartWay Program and California's end use 

4 regulation. Due to the agencies' decisions to rely on 

5 primarily proven, available, cost-effective 

6 technologies, the agencies can shift the standards 

7 forward by three years from 2027 as proposed forward to 

8 2024. This would allow sufficient lead time still for 

9 manufacturers and truck buyers to gradually incorporate 

10 the technologies into their operations over the next 

11 nine years. 

12 We have noticed several areas where the agencies 

13 do not fully incorporate available technologies. One 

14 area is in the engines where Agencies -- the agencies 

15 have proposed to reduce tractor diesel engine fuel used 

16 by four percent from 2017 to 2027. Available 

17 technologies with payback periods comfortably less than 

18 two years that can reduce new diesel tractor engine

19 fuel use fleet wide by up to 10 percent from 2017 to 

20 2027 based on our own technical analysis as well as the 

21 research literature. Even higher technology 

22 penetration rates with U.S. DoE's super truck 
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1 technologies would mean the standards could go further 

2 yet. 

3 In addition, the proposed heavy duty pickup and 

4 van as well as the gasoline engine efficiency standards 

5 appear to fall significant short in their promotion of 

6 the full technology potential. Finally, this 

7 rulemaking is key in establishing the U.S. as a global 

8 leader on freight truck efficiency. The governments of 

9 Canada, China, Europe, India, Japan, Mexico, and others 

10 are also considering their next policy actions to 

11 similarly ensure greater efficiency technology 

12 deployment in trucks. The world is watching and 

13 potentially looking to adopt similar policy. 

14 We are glad to provide the references with the

15 technical research that supports these statements, and 

16 we, of course, will elaborate on these points in our 

17 detailed comments that we'll submit to the docket. 

18 Again, we thank the agencies for their exemplary public 

19 service. 

20 MR. GRUNDLER: Thank you very much. Mr. 

21 McAlinden? 

22 MR. MCALINDEN: Thank you. Good morning. I'm Ken 
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1 McAlinden, the advanced heavy duty regulation 

2 supervisor for Ford Motor Company. It's a pleasure to 

3 be here today to provide our perspective on this very 

4 important rulemaking. 

5 We commend the efforts of the EPA and NHTSA in the 

6 difficult task of developing this second phase of their 

7 greenhouse gas emissions and fuel efficiency standards 

8 for medium and heavy duty engines and vehicles. 

9 Moreover, we commend the agencies for working closely 

10 with the California Resources Board in developing these 

11 proposed standards. We are committed to working with 

12 EPA, NHTSA, and ARB to finalize these regulations as a 

13 single national program that would allow manufacturers 

14 to continue to build a single fleet of vehicles and

15 engines. 

16 Before I talk about the proposed rulemaking, I’d 

17 like to spend a very brief moment telling you about the 

18 progress that Ford is making in executing our long-term 

19 sustainability plan. Since the Phase 1 heavy duty 

20 greenhouse gas requirements were promulgated, Ford 

21 introduced a whole new line of full-sized vans called 

22 Transit, which feature fuel efficient V-6 and 
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1 turbocharged gasoline engines as well as a small 

2 displacement five-cylinder diesel engine. Ford's 

3 complete and incomplete vehicles in this segment 

4 consist of Transit Econoline vans, F Super Duty trucks, 

5 and motor homes. 

6 Ford is investing billions of dollars over the

7 next five years to introduce technologies that improve 

8 fuel economy and reduce the greenhouse gas emissions of 

9 our fleet. We're driving innovation in every part of 

10 our business to deliver advanced new products and to 

11 change the way the world moves. Commercial truck 

12 customers demand technologies that provide value for 

13 money while providing truck functionality, whether it's 

14 volume for people or cargo, the ability to haul large 

15 loads, or to work off road. 

16 Fuel economy continues to be very important to our 

17 commercial truck customers, and Ford has invested in 

18 technologies to maintain customer satisfaction. You 

19 will continue to see us offer more great products with 

20 advanced innovative technologies to improve the fuel 

21 efficiency of our vehicles and to deliver outstanding 

22 quality and features that our customers desire. 
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1 Turning now to the proposed rule making, Ford 

2 supports the continuation of the harmonized greenhouse 

3 gas emissions and fuel consumption regulatory framework 

4 for the over 8,500-pound vehicles. The phase 2 

5 proposal offers challenging greenhouse gas and fuel

6 economy targets, particularly in the context of new

7 emission standards and changes to test fuel properties 

8 in that same time period. These external factors 

9 increase the effective stringency in technology-forcing 

10 aspects of the heavy duty greenhouse gas proposal 

11 beyond what the numerical value of the standards alone 

12 would suggest. 

13 As mentioned earlier, we offer essentially two

14 types of complete vehicles: vans and pickup trucks and 

15 variations of those. Therefore, it is of critical 

16 importance to provide manufacturers with adequate lead 

17 time to meet the requirements. As with Phase 1, the 

18 proposal includes a range of compliance mechanisms,

19 such as the ability to carry forward credits from prior 

20 model years as well as vocational vehicle and engine 

21 averaging banking and trading provisions. 

22 Ford supports expansion of the Phase 1 allowance 
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1 to generate emission credits for CO2 improvements for 

2 technologies providing on road fuel consumption 

3 benefits that are not captured by the emissions test 

4 cycles or models. Ford supports the establishment of 

5 standards that recognizes the needs of the trucking

6 industry and other commercial users, increase the use 

7 of known technology found to be feasible and effective 

8 in the market segment, preserve the utility and 

9 functionality of these commercial vehicles, including 

10 maintaining separate gasoline and diesel targets, are 

11 compatible with the complexities of the marketplace, 

12 and avoid unintended consequences. 

13 Ford has some concerns with the accuracy of the 

14 greenhouse gas emissions model used to determine 

15 compliance for vocational vehicles, particularly in the 

16 case of vehicles with heavy duty gasoline and light

17 heavy duty diesel engines. Ford recommends that data 

18 is used to validate the model for these engines and

19 vehicles. Ford will provide detailed written comments 

20 on this subject once we have fully evaluated the model. 

21 We'll continue to cooperate with EPA and NHTSA 

22 requests for data to support the refinement of the GEM 
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1 model. 

2 Finally, Ford recognizes the benefits for the 

3 country of continuing a uniform national program to

4 address greenhouse gases and fuel efficiency for medium 

5 and heavy duty vehicles The EPA and NHTSA Phase 1 

6 proposal was the first step to providing the clarity, 

7 certainty, and flexibility necessary to achieve the

8 aggressive greenhouse gas emission reduction goals that 

9 we all share. The proposed Phase 2 builds and expands 

10 on this progress, setting challenging targets for 

11 industry for the next decade. 

12 Once again, Ford appreciates the opportunity to 

13 provide our testimony on this important rulemaking. We 

14 are continuing to review all of the technical aspects 

15 of the proposal, and we plan to provide detailed 

16 written comments aimed at achieving and finalizing 

17 regulations consistent with the commitment that all

18 parties have made to this national program. 

19 Thanks, and I'll be happy to answer any questions. 

20 MR. GRUNDLER: Thank you. Mr. Mathers. 

21 MR. MATHERS: Great, thank you. Jason Mathers, 

22 Environmental Defense Fund. On behalf of the 
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1 Environmental Defense Fund and our more than one 

2 million members nationwide, I sincerely thank you for 

3 the opportunity to testify today. 

4 Freight trucks are one of the fastest-growing 

5 sources of climate disrupting emissions. Leaders in 

6 business and the environmental community alike 

7 recognize that rigorous, well-designed standards can 

8 save fleets and families in fuel costs, can reduce 

9 dangerous pollutants, and can strengthen our global

10 competitiveness by spurring the deployment of existing 

11 technologies. In fact, in a recent Wall Street Journal 

12 op-ed, Fred Krupp, president of EDF, joined with Indra 

13 Nooyi, chairman and CEO of Pepsico, in a call for 

14 strong Federal standards to reduce fuel consumption and 

15 greenhouse gas emissions from heavy trucks. 

16 Now, as proposed, the heavy truck fuel efficiency 

17 and greenhouse gas standards are an important step 

18 forward, but they fall short of being the strong 

19 standards our Nation needs. We need final Phase 2 

20 standards that are built to enable innovators to 

21 advance further in their efforts to spurring 

22 technologies that can achieve deeper emissions 
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1 reductions and greater efficiency improvements. 

2 Standards that are lacking currently current available 

3 technology would be a terrible misread of the market 

4 demand, and would fail to carry out the technology 

5 spurring statutory requirements of the Nation's clean 

6 air laws. 

7 We respectfully make the following recommendations 

8 to realize the economic and environmental opportunities 

9 of protective standards. Number one, strengthen the 

10 engine standard. And engine standard is essential for 

11 several reasons, including the ability to deliver 

12 permanent, real world results, and allowing EPA and

13 manufacturers to simultaneously evaluate NOx and CO2 

14 emissions, ensuring that efficiency improvements do not 

15 result in higher NOx and emissions. 

16 Existing technologies have the potential to cost17 effectively reduce engine fuel consumption by more than 

18 15 percent beyond the 2017 levels. Through the 

19 impressive results of the Super Truck Program, advanced 

20 technologies are demonstrating the ability to achieve 

21 even greater reductions. Engine improvements on the 

22 order of 15 percent will deliver cost savings for end 
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1 users. Analysis by Andrew Bally and Associates found 

2 that the final standard consistent with a 50 percent 

3 engine standard would reduce the total life cycle cost 

4 of owning a new super combination truck by 22 cents per 

5 mile in 2030, saving fleet owners and their customers 

6 tens of billions annually. 

7 The second recommendation is to accelerate the

8 timing of the most stringent standards to 2024. The 

9 compliance timeline in alternative four is consistent 

10 with our assessment of the appropriate timeframe for 

11 implementing the most stringent standards. Nearly a 

12 decade away, it provides sufficient lead time for 

13 manufacturers to cost-effectively scale fuel saving

14 solutions. It also better reflects the urgent need to 

15 reduce climate disrupting emissions. 

16 The third recommendation is to ensure emissions 

17 reductions regardless of fuel choice. Diesel is 

18 currently the dominant fuel for heavy trucks. While 

19 it's likely to remain the most widely used fuel 

20 throughout the Phase 2 proposal, gasoline and natural 

21 gas trucks are making inroads in different market 

22 segments. The agencies need to safeguard projected
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1 savings by -- from being eroded by lower standards for 

2 other fuels or perverse incentives in the rule. 

3 EDF Is particularly concerned about the ability of 

4 natural gas trucks to deliver real world greenhouse gas 

5 reductions. Given the significant impact of upstream 

6 methane emissions, a recent ICCT study found that 

7 "Inadequate attention to technologies designed to limit 

8 methane leakage would diminish the program benefits by 

9 as much as 38 percent." This is simply not acceptable. 

10 The proposal takes important steps forward in 

11 respect to its treatment of methane emissions from 

12 natural gas trucks. The requirement that natural gas 

13 engines have closed crank cases and the establishment 

14 for the first time ever of whole time requirements for 

15 L and G takes are important. While it's critical for 

16 the EPA to carry out the President's January 2015 

17 commitment to secure a 40 to 45 percent methane 

18 reduction by adjusting the leak discharges and venting 

19 associated with oil and gas development, there are 

20 several additional steps the Agency can take under this 

21 rulemaking to further address the impact of methane

22 emissions. 
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1 First, the Agency should use the current global 

2 warming potential values put forward by the IPCC. 

3 Second, the Agency should recognize the full impact of 

4 methane by accounting for its impact in multiple time 

5 periods. Third, the Agency should adopt the full fuel 

6 cycle accounting approach for alternative fuels which 

7 the Agency chose to pursue in historic light duty 

8 standards. 

9 The agencies need to act on gasoline, too. It is 

10 inconsistent with the mandate of these Agencies to 

11 continue to hold diesel and gasoline to different 

12 standards. We urge you to decrease the gap between the 

13 diesel and gasoline standards over the Phase 2 program 

14 in order to completely phase out separate standards. 

15 In sum, there are cost-effective and workable steps the 

16 agencies can take to finalize strong standards that

17 will save tens of billions annually for the U.S. 

18 economy, support American innovation, and reduce 

19 greenhouse gas emissions on an absolute basis. 

20 To close, though, I want to note that as important 

21 as strong rules are to me professionally, it is 

22 essential to me personally. Two months ago I was 
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1 blessed with the birth of a second child. Climate 

2 change will be a consistent challenge for his 

3 generation. He will turn 35 in 2050 when our best 

4 science tells us that we must have emissions down 80 

5 percent to avoid the worst impacts of a warming world. 

6 As much faith as I have in his ability and that of his 

7 generation, it is irresponsible for us to burden him 

8 with the immense challenges of a warming world. 

9 While this effort is but one of the many needed, 

10 the responsible course of action is to maximize the

11 adoption of cost-effective fuel-saving technologies

12 that exist today. Thank you. 

13 MR. GRUNDLER: Thank you, Jason. Congratulations 

14 on your new son. 

15 MR. MATHERS: Thank you. 

16 MR. GRUNDLER: Chris Hess. 

17 MR. HESS: Well, good morning. I'm Chris Hess, 

18 director of public affairs for Eaton. I'm representing 

19 our vehicle group this morning, and I appreciate the 

20 opportunity to give testimony regarding Phase 2 of 

21 greenhouse gas emissions rules for commercial trucks. 

22 Eaton is the power management company with 2014 
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1 sales of $22.6 billion. We provide energy efficient 

2 solutions that help our customers effectively manage 

3 electrical, hydraulic, and mechanical power more 

4 effectively, safely, and sustainably. Eaton has 

5 approximately 102,000 employees globally and sells 

6 cells products to customers in over 175 countries. Our 

7 vehicle group is a leader in the design, manufacture, 

8 and supply of drivetrain and powertrain systems and

9 critical components that reduce emissions and improve 

10 fuel economy, stability, performance, and safety of

11 cars, light trucks, and commercial vehicles. 

12 Products include transmissions, clutches, hybrid 

13 power systems, superchargers, engine valves and valve 

14 actuation systems, engine controls for the global 

15 industry. The principal market for Eaton's vehicle

16 group are original equipment manufacturers and 

17 aftermarket customers of heavy, medium, and light duty 

18 trucks, SUVs, passenger cars, and agricultural 

19 equipment. 

20 First and foremost, Eaton appreciates the approach 

21 taken by both the U.S. EPA and NHTSA to reach out to 

22 stakeholders in the industry for in-depth technology 
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1 discussions early in the development of Phase 2. It 

2 cannot be said that the agencies did not listen to the 

3 thoughts and concerns of commercial vehicle industry 

4 and other stakeholders who are part of the commercial 

5 vehicle value chain in the United States. 

6 As we did in Phase 1, Eaton supports the approach 

7 for a new generation of clean fuel efficient, 

8 commercial vehicles that will reduce greenhouse gas

9 emissions and strengthen the U.S. economy. Phase 1 has 

10 been successful in that it put together a sound 

11 regulatory framework that is aligned with market forces 

12 to drive adoption of the most efficient commercially13 available technologies. 

14 By following the structure created in the Phase 1 

15 for Phase 2, the agencies can rely on a proven concept 

16 that will build upon established regulatory structure, 

17 testing and processes that are efficient and fair. We 

18 are encouraged to see that the rule implements 

19 performance-based standards to ensure that the fuel

20 savings certified by the test procedures end up as 

21 benefits to truckers and fleets on the road. 

22 Eaton believes that the separate engine and 
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1 vehicle standards found in Phase 1 should be maintained 

2 in Phase 2. The separate standards reflect the reality 

3 of the commercial vehicle market, drive adoption of

4 efficient technologies, and provide a structure that is 

5 proven and accepted in the U.S. market today. Eaton is 

6 also encouraged that the proposed rule calls for a 

7 long-term regulation. This will provide regulatory

8 certainty that will help companies like Eaton focus our 

9 industry efforts on investments in advanced 

10 technologies aimed at significant fuel savings. This 

11 regulatory clarity in the market is critical as it 

12 allows Eaton and others time to work with our customers 

13 in the near, mid, and long term to develop technology 

14 solutions to meet the prescribed standards with the

15 reliability, safety, and performance demanded by our 

16 customers and trucking fleets. 

17 Furthermore, we're pleased that the EPA is 

18 expanding utilization of the powertrain test option

19 introduced in Phase 1 for hybrid certification. The 

20 powertrain test accurately measures the fuel benefits 

21 of advanced technologies in realistic driving 

22 conditions. We believe that the powertrain test is a 
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1 critical component to model-based certification. The 

2 fact that the benefits of advanced transmissions and 

3 controls are all visible in the powertrain test enables 

4 OEMs to achieve compliance through technologies in a 

5 cost-effective fashion. 

6 Eaton believes that deep engine and transmission 

7 integration, dual clutch technologies, and ultra 

8 efficient transmissions are cost-effective ways to save 

9 fuel that achieve compliance without adding weight,

10 cost, and complicity of some of the new and untested 

11 technologies. We believe that powertrain test option 

12 ensures the promise of these technologies will be 

13 realized in the commercial vehicle market. 

14 The proposed rule is a good foundation for what 

15 the new regulations can be, giving clear, achievable 

16 objectives that spur innovation development while 

17 avoiding a negative impact on the economy, and 

18 promoting leadership in commercial vehicle efficiency. 

19 Eaton Believes that many of the technologies needed to 

20 achieve the proposed standards are available, some in 

21 low-volume production, and others need a path into the 

22 market that recognizes and values contributions to 
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1 emissions reduction and fuel efficiency. 

2 It is important that Phase 2 provide clear and

3 realistic targets for the industry to accelerate 

4 adoption of new technologies. Eaton is looking forward 

5 to submitting -- supporting the rulemaking process with 

6 comments to U.S. EPA and NHTSA on the proposed rule in 

7 the near future. Thank you for your attention. 

8 MR. GRUNDLER: Well done. Let's see if Mr. 

9 Tonachel can do as well. Welcome. 

10 MR. TONACHEL: Good morning. My name is Luke 

11 Tonachel, and I direct the Clean Vehicles and Fuels

12 Project at the Natural Resources Defense Council, or 

13 NRDC. On behalf of NRDC's more than two million 

14 members and online activists, I appreciate the 

15 opportunity to testify today. 

16 As you know better than most, the Phase 2 medium 

17 and heavy duty truck proposal is the result of a 

18 tremendous amount of work. NRDC thanks you and your 

19 staffs for the -- for the fair and inclusive rule 

20 development process conducted by the agencies which

21 included hundreds of meetings with stakeholders, 

22 including those meetings with us in the NGO community 
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1 speaking on behalf of the public's environmental 

2 concerns. 

3 And healthy environment and our clean energy 

4 future depend on strong greenhouse gas and fuel 

5 efficiency standards for heavy trucks. The latest 

6 projection from the Energy Information Administration 

7 shows that medium and heavy trucks will be the fast8 growing source of oil demand and carbon pollution in 

9 the transportation sector if new truck standards are 

10 not implemented. NRDC Believes these standards are

11 integral and critical part of the President -- of 

12 President Obama's climate action plan. 

13 The proposed standards include some very important 

14 steps forward. For example, adding trailers to the

15 truck rules can deliver significant efficiency 

16 benefits. Also the agencies made improvements to 

17 regulatory compliance tools, such as the GEM model and 

18 the vocational truck segmentation and duty cycles. 

19 At a high level, I would like to highlight to 

20 areas where the agencies should modify the proposal. 

21 First, the compliance timeline should be moved up. The 

22 environmental community conducted conservative analysis 
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1 showing that the new fleet fuel consumption and 

2 greenhouse gas emissions can be reduced by at least 40 

3 percent from 2010 levels by 2025. Within the proposal 

4 alternative four, which achieves full compliance in

5 2024, is the closest to meeting our target. When it 

6 comes to cutting carbon and reducing our dangerous 

7 dependence on oil, every year counts. 

8 The agencies' own analysis shows that alternative 

9 four is technically feasible and cost effective. NRDC 

10 believes that the 2024 compliance timeline is also 

11 appropriate. Compared to the proposal, alternative

12 four reduces oil consumption and carbon pollution by an 

13 additional 13 percent, and increases net benefits by 

14 over $24 billion. NRDC urges the agencies to 

15 accelerate the compliance timeline. 

16 Second, NRDC believes that the engine standard

17 should be significantly strengthened. As proposed, the 

18 engine standard is weak because it achieves only a 4.2 

19 percent emissions reduction over 10 years. In reality, 

20 the standard is even weaker, and close to 3 percent

21 because the proposed rewriting of the supplemental 

22 emissions test, or SET, toward lower engine speeds 
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1 results in better performance on the test without any 

2 new technology addition. 

3 NRDC supports the structure of a separate engine 

4 standard because we think it's necessary to ensure that 

5 all cost-effective engine efficiency technologies will 

6 be applied to the engine. However, the proposed engine 

7 standard appears too modest to drive the full speed of 

8 existing technology adoption, and certainly fails to be 

9 technology forcing. We urge the agencies to strengthen 

10 the energies standard. 

11 NRDC believes that the strong engine standard and 

12 vehicle standards are important for improving the 

13 industry's competitiveness and supporting manufacturing 

14 jobs. Strong fuel efficiency standards promote 

15 technology innovation and adoption. When more 

16 technology is added to vehicles, demands for labor, and 

17 therefore jobs, are increased. 

18 Working with the Blue Green Alliance, NRDC is 

19 assessing U.S. jobs associated with making and applying 

20 technologies that improve fuel efficiency in medium and 

21 heavy duty trucks. We believe that the standards can 

22 boost manufacturing jobs across the country. Today
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1 more than 36,000 engineers, technicians, and assembly 

2 workers are employed in over 300 in 80 facilities 

3 across the 48 -- 43 states to develop, design, and 

4 build components in trucks that help quality using less 

5 fuel. 

6 Fuel efficiency and carbon pollution standards

7 also help make all truck manufacturers more 

8 competitive. Compared to their fuel cousin 

9 predecessors, fuel efficient trucks will be less 

10 vulnerable to sales decline when diesel and gasoline 

11 prices spikes. Also, standards-driven technology

12 advancements will put U.S. manufacturers in a 

13 leadership position on international -- on the 

14 international market. 

15 NRDC believes that strong fuel efficiency and 

16 carbon pollution standards are good for the economy and 

17 for the environment. We greatly appreciate the hard 

18 work of the agencies on this comprehensive and thorough 

19 proposal. As I've described today, there are 

20 opportunities to strengthen the standards and to 

21 maximize the benefits to our Nation. NRDC looks 

22 forward to working with the agencies to make 
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1 improvements to the final rule. Thank you very much. 

2 MR. GRUNDLER: Thank you, and I appreciate the

3 panel's effort to get us back on schedule after the

4 first speaker. 

5 (Laughter.) 

6 MR. GRUNDLER: I do have a few questions, and I'll 

7 see if the other panel members have. Starting with Mr. 

8 Mandel, on the NOx question, we spent some time in the 

9 proposal discussing the need for further NOx 

10 reductions, particularly in California based on the

11 current ozone standard. You know that the agency has a 

12 decision to make in October about strengthening that 

13 ozone standard, so we certainly heard from California 

14 and others about their interest in further NOx 

15 reductions. So I was intrigued by your statement that 

16 says your members are -- make sure I get a correct here 

17 -- remain open to hearing from us. 

18 So my question, and I don't know if you're 

19 prepared to answer this today, but in addition to 

20 hearing from us, are you suggesting there's an 

21 opportunity for the agencies to work with your members 

22 on future NOx reductions? We know it's not part of
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1 this rule. We want to be clear on that. But given the 

2 October 1st decision that we'll be announcing, and the 

3 needs we've already heard from given today's ozone 

4 standards, and the fact that millions of Americans 

5 continue to breathe unhealthy air, what can we expect 

6 from your members on this question? 

7 MR. MANDEL: Well, first of all, you asked me a 

8 question, so I got the microphone back. But I'll get 

9 it over it, I'm sure. 

10 You know, we are -- we've had conversations with 

11 California. We're very much aware of California's 

12 ozone problem. We are less certain as to what the 

13 solution is, including whether the solution is a 

14 further reduction on the NOx emissions out of brand new 

15 trucks as opposed to other sources of pollutants that 

16 contribute to the ozone problem. 

17 Having said that, were also mindful of the ozone 

18 rule that is likely to be or will be finalized in 

19 October. We know that California is pushing the 

20 agency, EPA, hard on lower NOx standards. So we do

21 want to hear from you. We want to hear from both their 

22 resources board and EPA as to what they think the 
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1 possible course might be, including setting priorities. 

2 Clearly the priority today is greenhouse gas 

3 reductions associated with fuel efficiency 

4 improvements. 

5 There's a tradeoff between NOx and GHG. We need 

6 to hear as to whether one is a priority over the other 

7 in order to assess how we can ultimately work to 

8 potentially improve both. So we need to hear more. 

9 Frankly it may be more than just a -- an emission to 

10 limit problem. There's questions about the test 

11 procedure and where those NOx emissions are coming 

12 from. It would be, I think, a bad mistake to just 

13 lower the limits on NOx and not try to figure out where 

14 NOx emissions are actually contributing to a potential 

15 inventory that's affecting ozone compliance. 

16 So there's -- it's a complicated issue. We will 

17 obviously want to talk with you, your colleagues in

18 California, and hear where we might be able to go. And 

19 as I think as this industry has been for a long time, 

20 we prefer to be part of the solution. And in that 

21 regard, we're always willing to work with the agencies, 

22 but we want to make sure we understand what the problem 
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1 is we're trying to solve. 

2 MR. GRUNDLER: Fair enough. You noted the 

3 complexity of a 1,280-page modest proposal, and the

4 variability, and the need for margins. So the agencies 

5 face somewhat of a dilemma because one of our top 

6 priorities is making sure that the standards provide 

7 real world emission reductions. That contributes to 

8 the complexity and the assurance that the agencies are 

9 looking for, that the standards and these test 

10 procedures and all these inputs are real, and are 

11 providing these real world reductions. 

12 Do you or your members have suggestions on how to 

13 accomplish both of these goals, because if we can make 

14 it simpler, you know, we will be interested. But 

15 simplicity at the cost of assurance of real world 

16 reductions so that customers are realizing the benefits 

17 of these better trucks is our highest priority. 

18 MR. MANDEL: And I'm glad you asked me about that 

19 because we share a common view. This is all about real 

20 world reductions. Unlike the history we have of 

21 working together to achieve criteria pollutant 

22 reductions where our customers aren't always assured 
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1 that they really want those, they want fuel efficiency 

2 improvements. They want lower greenhouse gas 

3 emissions. And they're incredibly sophisticated and 

4 know better than probably any of us for their 

5 particularly -- their particular truck, their 

6 particular delivery schedule, where their goods are

7 being moved and what type of goods they are, how best 

8 to get that fuel efficiency. We think the marketplace 

9 has a significant role here. 

10 We understand and have been a party to assisting 

11 both EPA and NHTSA to make GEM more sophisticated than 

12 in Phase 1. We're also aware that the agencies want to 

13 assure that when manufacturers make their GEM 

14 calculations, that there's some verification of that 

15 process. But what -- but what I was particularly 

16 referring to in my testimony is that the verification 

17 of that process with the proposed coast down test when 

18 there are an enormous number of variabilities in just 

19 right to assure, again, that GEM calculation, that's 

20 where we have to work to eliminate the variabilities to 

21 an extent possible. 

22 Many of them don't exist in Phase 1 because the -- 
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1 everybody tested on the same track, for example. So if 

2 there's testing on variable tracts, it adds 

3 variability, and obviously there's more variability in 

4 GEM in the proposed Phase 2 rule. We think we can work 

5 on those things, but the fact of the matter is that

6 whatever the coast down test is are not the conditions 

7 that our customers are actually using the trucks, and 

8 that's what drives the real world fuel efficiency. 

9 So if they're going to buy what they feel they

10 need to achieve their best fuel efficiency, their best 

11 greenhouse gas reductions for their particular freight 

12 service, the mission that they have to accomplish, 

13 frankly probably irrespective of what the GEM 

14 calculation is and the coast down test verification. 

15 But we want to make sure that we don't inadvertently 

16 fail that point, and in order to provide ourselves 

17 margin that the rule may not yet provide, downgrade

18 where we have to certify an aerodynamic feature of a 

19 tractor such that we actually don't comply with the

20 rule. We have to give ourselves our own margin by 

21 aiming lower into a lower aero-band, and that just 

22 doesn't help anybody. 
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1 MR. GRUNDLER: Fair enough. Thank you. I’d like 

2 to introduce my esteemed counsel, Steve Silverman, who 

3 just joined us. Welcome. Mr. Lutsey, I want to thank 

4 you for providing all of your sites to your remarks. 

5 That's going to be very, very helpful. And you also 

6 noted some new ICCT research studies. I can trust that 

7 you'll be providing that data through your written 

8 comments? 

9 MR. LUTSEY: Of course. 

10 MR. GRUNDLER: Great. Thank you very much. 

11 Similarly to Ford, you know, we'd be very interested in 

12 receiving data to help us validate the proposed model. 

13 We want to make sure we get that right. Continuing 

14 the theme, Mr. Mathers, will EDF be providing 

15 information and data to support your assertion that a 

16 15 percent increase in stringency is feasible? 

17 MR. MATHERS: We will. 

18 MR. GRUNDLER: Great. And one more question for 

19 Luke. You mentioned a jobs assessment you're working 

20 on with the Blue Green Alliance. 

21 MR. HESS: That's right. 

22 MR. GRUNDLER: Will that be published in time to 
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1 submit to the agencies -- 

2 MR. HESS: It will. 

3 MR. GRUNDLER: -- because that's obviously a very 

4 important concern. 

5 MR. HESS: Yes. 

6 MR. GRUNDLER: That exhausts my questions. Any 

7 further questions from panel members? 

8 MALE VOICE: No further questions. 

9 MR. GRUNDLER: Thank you again for your time. 

10 We're very grateful. 

11 MR. TAMM: So if we can ask the panel that's in 

12 the staging area to come up to the main table, please. 

13 And then I would invite the third panel to go to the 

14 staging area. Again, that's the chairs over on the far 

15 side of the room. So the third panel, Erin Roth, 

16 Dennis Nelson, Joe Kubsh, Matthew Rudnick, David 

17 Chandler, Bob Keefer, Vice Admiral Ann Rondeau, and

18 Marcy Gustafson. 

19 Okay. I think we're ready to get started. Mr. 

20 Khan, when you're ready, please. 

21 MR. KHAN: Good morning, and thank you. So I'm 

22 Siddiq Khan, a senior researcher at ACEEE, American
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1 Council for an Energy Efficient Economy. It was 

2 founded in 1980 as a non-profit organization -- 

3 business organization that acts as a catalyst for 

4 energy efficiency policies, programs, technologies,

5 investments, and behavior. 

6 The adoption of the first ever greenhouse gas 

7 emissions and fuel efficiency standards for the heavy 

8 duty vehicles in 2011 was a historic step in reducing 

9 emissions in oil consumption from the transportation 

10 sector. The proposed phrase two standards, built on 

11 the success of the Phase 1 program, would provide 

12 substantial gains in fuel efficiency for heavy duty

13 vehicles by 2027, provide continuity and certainty to 

14 the manufacturers, deliver savings at the pump, and

15 reduce freight costs. The Heavy Duty Fuel Efficiency 

16 Program is also a key element of the President's 

17 climate action plan. 

18 ACEEE applauds the agencies' excellent work in

19 developing Phase 2 standards. The proposed rule 

20 improves upon the existing Phase 1 program in several 

21 ways. Number one, full vehicle integration. The 

22 greenhouse gas emissions model in GEM is more 
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1 sophisticated in Phase 2, which would allow many more 

2 technologies to contribute to the certified fuel 

3 efficiency. For example, transmission improvements

4 will register in the vehicle certification process for 

5 the first time. The vehicle certification protocols 

6 will promote integration of engine, transmission, and 

7 vehicle components. 

8 ACEEE strongly supports the agencies' proposal

9 that tractor and vehicle manufacturers -- vocational 

10 vehicle manufacturers be required to chassis test a

11 small number of vehicles each year in order to help

12 detect any discrepancy between emissions reductions

13 simulated in GEM model and reductions realized in 

14 vehicle operation. 

15 Number two, inclusion of trailers. This is a very 

16 critical and crucial benefit because known affordable 

17 trailer and tire technologies can deliver more than 10-

18 percent savings for tractor trailers. Number three, 

19 vocational vehicle segmentation and reweighting of test 

20 cycles. The additional vocational vehicle classes will 

21 better reflect vehicles' operating characteristics. 

22 Test cycle will match vehicles' real world duty cycle 
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1 much better than they do in the Phase 1 program, 

2 especially for the vocational vehicles for which an

3 idle cycle has been added to the certification 

4 protocol. 

5 Inclusion of road grade on the 55 and 65 miles per 

6 hour steady search cycles in Phase 2 will better 

7 reflect real world driving. Reweighting of the engine 

8 points -- operating engine operating points for tractor 

9 engine certification based on the real world is another 

10 positive. 

11 Yet the proposal can and should be standing in

12 several areas to capture more of the available fuel

13 savings and promote greater adoption of advanced 

14 technologies. First, the standard for diesel engine 

15 and tractor applications should be stringent to provide 

16 a strong incentive for manufacturers to make measured 

17 sustained investment in efficiency technologies over 

18 the next 15 years. The proposed four-percent 

19 improvement in engine efficiency falls far short of

20 what can be achieved, and should be stringent to at

21 least 10 percent in our assessment. 

22 Gasoline engine efficiency for vocational 
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1 vehicles, which would remain unchanged under the 

2 proposal, should continue to improve in order to 

3 deliver greater fuel savings and avoid upsetting the 

4 diesel gasoline balance of vocational vehicles. Fuel 

5 efficiency requirements for heavy duty gasoline pickups 

6 and vans should be more consistent with their light

7 duty counterparts. As proposed, the weight adjusted 

8 fuel economic target for the Ford 250 heavy duty pickup 

9 truck in model year 2025 will be 33 percent lower than 

10 the target for the Ford 150 light duty pickup, with

11 similar engine and transmission aspects. Such a large 

12 discrepancy in fuel efficiency targets for light and 

13 heavy duty pickups could result in market distortions 

14 and cost heavy pickup owners money at the pump. 

15 Number four, consumer fuel efficiency levels 

16 similar to those for cars and light trucks should be 

17 required for heavy duty pickups and vans. And number 

18 five, the Phase 2 standards proposed for 2027 can and 

19 should be moved forward to 2024. Most of the fuel 

20 saving technologies needed for Phase 2 compliance are 

21 available in the market today, and they will be 

22 available within in the next few years. 
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1 To conclude, ACEEE strongly supports EPA and 

2 NHTSA's Phase 2 greenhouse gas and fuel efficiency 

3 standards for heavy duty vehicles and engines. The

4 proposed rule built on the substance of the first phase 

5 represents another important step managing fuel 

6 consumption and greenhouse gas emissions of the heavy 

7 duty sector. 

8 We recommend that the agencies trend in the 

9 proposed rule several ideas that I have mentioned to 

10 ensure that the Phase 2 program achieves maximum 

11 economic and environmental benefits. Thank you. 

12 MR. TAMM: Thank you, Mr. Khan. Mr. Oshnock? 

13 MR. OSHNOCK: Good morning. My name is Gary 

14 Oshnock. I'm the manager responsible for NAFTA fuel 

15 economy and greenhouse gas regulatory compliance at

16 FCAUS, LLC. 

17 The FCAUS product line features some of the 

18 world's most recognizable trucks and engines in this 

19 segment. Those trucks include the Class 2 through 5 

20 variants of our popular Ram pickup and our Class 2B Pro 

21 Master commercial vans. Our gasoline engines include 

22 the award-winning 3.6-liter Pentastar V6, and the 5.7-
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1 and 6.4-liter Hemi V8 engines. Diesel engines include 

2 our class-leading 6.7-liter Cummins Turbo Diesel I-6 

3 and our three-liter EcoDiesel I4. 

4 Thank you for the opportunity to speak here today 

5 and show support for the U.S. EPA and NHTSA efforts to 

6 develop the second set of greenhouse gas and fuel 

7 consumption rules for the medium and heavy duty vehicle 

8 segment. We fully support and commend this 2019 

9 through 2027 model year Phase 2 initiative as we did 

10 the collaboration that produced the national Phase 1 

11 rule. FCAUS remains committed to the proliferation of 

12 clean technology and reducing vehicle operating costs 

13 while ensuring our products continue to deliver the

14 performance and functionality our customers demand and 

15 deserve. 

16 As EPA and NHTSA noted in the light duty program, 

17 a single national program holds out the promise of 

18 delivering environmental and energy benefits, cost 

19 savings, and administrative effectiveness that might 

20 not be available under a less coordinated approach. 

21 FCAUS unequivocally agrees. 

22 While we are still analyzing the proposed rule, I 
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1 have a few initial comments and suggestions. We 

2 continue to support EPA and NHTSA's attribute-based

3 standards that recognize the utility and functionality 

4 of these work trucks. Payload and towing capacity are 

5 important to the owners of these work trucks. These 

6 work factor-based standards acknowledge the inherently 

7 higher greenhouse gas emissions and fuel consumption of 

8 higher capability vehicles. 

9 While the light duty fleet has been regulated 

10 under NHTSA's Café Program for roughly 40 years, we are 

11 still very early in the Heavy Duty Program. We 

12 formally have one full model year of industry data 

13 under our belt. Given this limited baseline of real 

14 data, it is concerning that there have been calls for 

15 even greater stringency beyond the aggressive standards 

16 proposed by EPA and NHTSA for Phase 2. Comments 

17 regarding stringency need to address the many 

18 contributing factors, both explicit and implicit. 

19 These factors include, but are not limited to, the fact 

20 that these are work trucks, and there's a wide range of 

21 duty cycle so the values of the different technologies 

22 vary from a customer perspective. 
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1 We're challenged by year-over-year stringency 

2 increases with effectively only two products, a pickup 

3 truck and a van, to average in the 2B and 3 segment. 

4 The concurrent stringency increases, I think Ford 

5 mentioned earlier in the II and LEV III criteria 

6 emission requirements and how to manage the increased 

7 thermal loads on the after treatment systems while we 

8 continue to improve fuel economy. 

9 The impact of changing test fuels and the test

10 procedure adjustments that will be needed are unknowns 

11 at this point. Additional technology will be needed 

12 going forward given that some of the Phase 2 

13 technologies are already in our fleet today. We have 

14 to take that into account, for example, FCAUS cylinder 

15 deactivation and cool EGR in today's vehicles, making 

16 these technologies unavailable for improvements in 

17 Phase 2. 

18 FCAUS strongly believes that a single national

19 fuel consumption and greenhouse gas program will place 

20 more clean and fuel efficient vehicles on the road 

21 quickly and at a lower cost. Our resources are best 

22 utilized when applied to one single national standard 
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1 versus different state level fuel consumption and 

2 greenhouse gas requirements. 

3 As far as A/C system improvements, we believe 

4 there is value in recognize the greenhouse gas and fuel 

5 consumption contributions from reducing the energy 

6 demand of the A/C systems. We also believe there's

7 additional opportunity to further harmonize with the 

8 Light Duty Program and recognize the added greenhouse 

9 gas emission benefit beyond leak reduction. That's

10 switching to a lower global warming potential a 

11 refrigerant can provide. 

12 We support the flexibility mechanisms that are

13 included in the rule, averaging, banking and trading, 

14 and the recognition of the benefits of technologies

15 that are not fully captured on the laboratory drive

16 cycles. We will work with the agencies to make these 

17 processes more efficient in the second phase of this 

18 program. 

19 In closing, FCAUS will continue reviewing the 

20 proposed rule and submit these and other comments as 

21 part of the formal rulemaking process. We will work 

22 with EPA and NHTSA and other stakeholders to ensure
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1 that an implementable rule is finalized on schedule. 

2 Thank you. 

3 MR. TAMM: Thank you, Mr. Oshnock. Ms. Nichols? 

4 MS. NICHOLS: Thank you very much for the 

5 opportunity to testify today. My name is Kelly 

6 Nichols, and I am a lead organizer of the national non7 profit Moms Clean Air Force here in Illinois. We are a 

8 community of more than half a million moms and dads who 

9 are fighting for clean air and a safe climate for our 

10 kids. Here in Illinois we have over 20,000 members of 

11 our organization. 

12 I have three-and-a-half year old twins, and I live 

13 in Highland Park, Illinois, not far from Route 41 and 

14 Interstate 94. The proposed clean truck standards will 

15 make our freight trucks cleaner and more efficient for 

16 years to come, which is a step in the right direction 

17 for children's health. But while the proposed 

18 standards are a good first step, I urge you to 

19 strengthen these standards to ensure the greatest 

20 reductions in oil use and global warming emissions.

21 My son has already manifested symptoms indicating 

22 that he will likely have outdoor allergies like his
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1 father and I do. With the increase in extreme weather 

2 events due to climate change, which here can occur as 

3 very, hot humid days, I've noticed many more ozone 

4 alerts. And I know for me on days when there are ozone 

5 alerts, my symptoms get worse. 

6 I don't want my child to be that miserable and not 

7 to be able to go outside and have a normal childhood 

8 where he can play. I see him get knocked around by

9 every virus that rolls through like a typical toddler 

10 and I'm concerned it makes him more vulnerable for 

11 asthma, which could easily be exacerbated by our 

12 proximity to major freight truck routes. 

13 While I, of course, am concerned about my child's 

14 health, I know that also frequently there are more 

15 freight depots and shipping companies in frontline 

16 neighborhoods where pollution is worse than in my neck 

17 of the woods. In Illinois, the rate of childhood 

18 asthma is at 13 percent, which is one percent higher 

19 than the national rate. The age adjusted asthma 

20 mortality rate here in Chicago is nearly five times

21 higher in non-Hispanic blacks than in non-Hispanic 

22 whites. This rule will have a significantly positive 
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1 impact on these affected communities. 

2 Not only will the rule have an impact on the 

3 health of children. If finalized as proposed, the 

4 standards would cut oil use by over a million barrels 

5 every two days. By not burning that oil, the United 

6 States would over the lifetime of trucks affected by 

7 the rule avoid one billion metric tons of global 

8 warming emissions. That's roughly equivalent to the 

9 emissions created by powering all U.S. households for a 

10 year. That creates not only cleaner air, but a future 

11 that our children can count on. 

12 I think we need to do more than the proposed 

13 standard. To protect our children, we need standards 

14 to be strengthened to achieve 40 percent fuel savings 

15 by 2025. If the final proposal is strengthened in this 

16 way, it would save an additional 200,000 barrels of oil 

17 per day and avoid an additional 40 million metric tons 

18 of global warming emissions annually, which is the 

19 equivalent to shutting down 12 coal-fired power plants. 

20 Imagine the incredible impact that would have on 

21 children's health and all of our futures. 

22 I support the effort to make our trucks more 
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1 efficient, and I urge you to finalize stronger 

2 standards that reduce trucks' fuel use by 40 percent by 

3 2025. This will help protect the health of my kids and 

4 my community now and in the future. Thank you very

5 much for the opportunity to testify to day. 

6 MR. TAMM: Thank you very much. Ms. Peck? 

7 MS. PECK: Thank you for the opportunity to speak 

8 with you this morning. My name is Kyla Peck, and I'm 

9 with the Moms Clean Air Force. I live in Lansing, 

10 Illinois, which is right off the expressway of 90/94. 

11 The proposed clean truck standards will make our 

12 freight trucks cleaner and more efficient for years to 

13 come. That helps children like me living with asthma. 

14 I lived with asthma all my life. Just last night I 

15 came home from vacation, and I had to take two 

16 breathing treatments, two puffs of Flovent, and a puff 

17 of Advair with only being home for seven hours. That 

18 was just last night. Imagine living with it for 18

19 years. 

20 Imagine waking up and your child tells you that 

21 she can't breath. That was my mom's experience when I 

22 was 10, and she gave the standard medication: a 
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1 breathing treatment. That didn't work that night. She 

2 gave liquid albuterol. That didn't work. She gave

3 another breathing treatment, and that did not work. 

4 And then she also gave me a steroid called prednisone, 

5 and that didn't work. So she rushed me up the street 

6 to the hospital advocate. And in the process of trying 

7 to get me admitted, I passed out, and she was very 

8 close to losing her 10-year-old daughter that day. 

9 That wasn't a fun experience for her. 

10 Imagine being a child and seeing all the other

11 children run freely, but you can't do the same because 

12 you're not close to your breathing treatment, and you 

13 won't be home for a while. I wasn't able to play 

14 sports in high school because my asthma is extremely 

15 hard to control. I wanted to run track, but I knew my 

16 asthma would cause me to quit. 

17 Reducing diesel emissions should be a number one 

18 priority. I've had the pleasure to walk outside and 

19 breathe in the fresh and have to take a puff of inhaler 

20 in order to breathe normally from the toxic fumes that 

21 are in the air. I urge everyone to wake up to the 

22 reality that people are suffering, and so are your 
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1 children. 

2 This can stop, but thank you for listening. 

3 MR. TAMM: Okay. Again, thank you very much for 

4 your testimony. Mr. Jorgensen? 

5 MR. JORGENSEN: Thank you, and good morning. I'm 

6 Eric Jorgensen. As chairman of the American Truck 

7 Dealers Division of the National Automobile Dealer's 

8 Association, I thank NHTSA and EPA for hosting today's 

9 hearing on the Administration's proposal to increase 

10 the fuel economy and GHG standards for medium and heavy 

11 duty truck vehicles, and engines, and light duty work 

12 trucks, and to establish new truck/trailer mandates. 

13 ATD represents some 1,800 franchised commercial 

14 truck dealerships that sell new and used motor vehicles 

15 and engage in service, repair, and part sales. 

16 Together, truck dealerships employ more than 100,000 

17 people nationwide. 

18 In addition to being ATD chairman, I am president 

19 of Sheriff Jones Enterprises, a multi-state medium and 

20 heavy duty truck dealership group headquartered in 

21 Heartland, Wisconsin. We currently sell Peterbilt,

22 Volvo, and Hino trucks, Ottawa yard tractors, and 
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1 Paccar Volvo and Cummins engines. Like most 

2 dealerships -- truck dealerships, we do not sell 

3 trailers. 

4 Before I get started, I’d like to thank EPA and 

5 NHTSA for taking the time last year to visit several 

6 truck dealerships, including my store in Grand Rapids, 

7 Michigan. 

8 During my short time today -- with you today, I'll 

9 focus on just a few key high-level issues of particular 

10 importance to truck dealerships. ATD intends to 

11 provide more detailed comments and suggestions in our 

12 written submittal. Specifically, I'll focus on why any 

13 Phase 2 truck and engine efficiency standards must be 

14 affordable and must not compromise performance, why

15 such standards must be uniform nationwide, and why 

16 doing this rule right is more important than doing it 

17 quickly. 

18 ATD is well aware of the mandate Congress set out 

19 in the Energy Independence and Security Act of 2007. 

20 Moreover, in February of last year, I listened with

21 keen interest as President Obama directed NHTSA and EPA 

22 to move forward with the second round of commercial
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1 truck GHG and fuel consumption standards. In my 

2 opinion, EPA and NHTSA have a tough job to do. In 

3 short, your task is to ensure that the outcome of this 

4 rulemaking will foster continuous improvements in fuel 

5 economy and GHG emissions performance while preserving, 

6 if not enhancing, current rates of fleet turnover. 

7 It's that simple. Cleaner, greener, new equipment 

8 will do nothing for the environment or for energy 

9 security until it is bought and placed into service, 

10 more often than not, replacing older, less efficient 

11 equipment. Consequently, your goal should be to hit a 

12 regulatory sweet spot by setting performance standards 

13 that result in new products that purchasers are willing 

14 and able to buy. 

15 No variable cost is more critical dealerships than 

16 fuel. Consequently, the overwhelming majority of 

17 customers who order new vehicles from one of our stores 

18 put some focus on fuel economy performance. To be 

19 sure, their primary focus is on those vehicle and 

20 drivetrain features that they believe are essential to 

21 meet their specific work and duty cycle needs. 

22 Nonetheless, although fuel economy performance will
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1 never rank first on a customer's list of purchase 

2 decision criteria, it will always be near the top. In 

3 fact, given my customers' relatively strong demand for 

4 fuel economy, it's fair to ask what market failure is 

5 the Administration trying to fix with its Phase 2 

6 proposal? 

7 Cost is always a concern. Some of the Nation's 

8 largest fleets, and even some of my customers, can 

9 afford to be early adopters and experiment with new

10 fuels and technologies even if they cost significantly 

11 more. However, the vast majority of prospective new 

12 truck buyers are businessmen and women who rationally 

13 pencil up front costs of vehicle features, especially 

14 during times when credit is relatively tight and their 

15 freight rates and profit margins are relatively low. 

16 In order to work, fuel economy GHG mandates 

17 considered for model years 2018 and beyond must pass 

18 economic muster. Remember my customers have options. 

19 Instead of choosing to buy new, cleaner, greener 

20 equipment, they can instead pay my service and parts 

21 operations to help them keep their existing vehicles on 

22 the road up to and including rebuilding engines or 
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1 vehicles. Alternatively, they can buy used trucks or 

2 tractors that meet their needs at lower cost than the 

3 equipment covered by new mandates. Any new mandates 

4 must be affordable to success in the marketplace. 

5 As I hope we all learned from the rollout of 

6 tailpipe standards in 2002, 2007, and 2010, any new

7 fuel economy GHG mandates must avoid compromising the 

8 performance of new vehicles. Prospective customers

9 will avoid like the plague vehicles they know or 

10 perceive will be less reliable or that will require

11 more intensive service, maintenance, and/or repair. 

12 Simply put, my customers will not invest in higher down 

13 time rates. In addition to higher operating costs,

14 tractors and trucks that don't move don't make money. 

15 And I can only say, too, the testimony that's been 

16 given already that it is very important for us that

17 there be one standard, and that is not driven by 

18 California, but is imported throughout the Nation. 

19 That being said, I thank you for your time and look

20 forward to questions. 

21 MR. TAMM: Okay. Thank you for your comments. 

22 Mr. Frank? 
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1 MR. FRANK: Thank you. I find it interesting that 

2 I'm on this panel with you as a former NADA member, and 

3 my father starting our family business in the 

4 automobile field as a Chrysler Plymouth dealer in 1936 

5 since Chrysler is here. 

6 My name is Chuck Frank, and I am here as a member 

7 of the Sierra Club and the first elected director from 

8 Illinois. And I hope that the fact that I'm just 

9 wearing a tee shirt and not a coat and tie doesn't 

10 affect my credibility since I do represent 2.4 million 

11 members and supporters of the Sierra Club, my MBA from 

12 the University of Chicago, our hometown place with a 

13 focus on economics and finance, and the fact that I ran 

14 our car business, a half a billion dollar business, for 

15 33 years selling Chevrolets as the largest Chevy dealer 

16 in the country, and other both domestic and imported 

17 products will provide the adequate credibility for my 

18 comments. 

19 You've already heard and will continue to hear a 

20 lot of comments and testimony from many experts and

21 others with lots of data, and research, and talking

22 points. I will spare you more of that and leave that 
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1 to them. I want to approach the topic today from a

2 different perspective: winners and losers. 

3 Let me start by advocating not only implementing 

4 the proposed standards, but strengthening them to 

5 achieve a 40 percent fuel savings by 2025. First, who 

6 are the winners? The first will be my wife, who has 

7 suffered also from asthma and has had many of the same 

8 circumstances as you. And as you know, it is 

9 distressing to get on the highway and not know whether 

10 you're going to be able to breathe because you're 

11 driving behind a heavy duty vehicle or a bus that is 

12 spewing out diesel emissions. 

13 It's also for my family are winners since we often 

14 don't know whether we're going to be able to follow

15 through with our plans not knowing whether my wife is 

16 going to be able to leave the home and breathe. And 

17 it's also -- winners are all the other people who have 

18 breathing problems and will benefit from this. 

19 The fourth winners are the schools. Asthma is the 

20 number one reason for children missing school, and the 

21 schools get their income from the students being at

22 school every day, so the schools will definitely 
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1 benefit. Chicago is ground zero with the highest rates 

2 of asthma in the country, especially on the South Side 

3 of Chicago with the highest incident rate of emergency 

4 room admissions due to asthma. Society, of course,

5 will benefit from better public health and, because of 

6 our children being able to go to school more days, a 

7 better educated community, and lower health costs. 

8 Businesses will win because when children stay

9 home from school, their parents -- one of the parents 

10 usually also has to miss work to take care of the child 

11 at home creating absenteeism and loss of productivity. 

12 Businesses will also benefit from lower healthcare

13 costs for their insurance and obviously greater 

14 productivity. 

15 Companies that provide the technology and the 

16 devices for the trucks will benefit. Truckers will

17 benefit from less fuel costs and fewer stops for fuel. 

18 Obviously the climate will benefit, and everyone who 

19 could be severely impacted by climate change. Our 

20 soldiers will be benefitted by not having to fight to 

21 keep oil fields around the world open, and our Federal 

22 budget will benefit from not having to have as big a 
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1 military and healthcare costs. And our wild lands will 

2 benefit from not being despoiled from drilling. 

3 So who loses? Quite frankly, nobody. Everybody 

4 is a winner. I've been in the car business for my 

5 entire career, and I have seen regulations promulgated 

6 over and over again, and industries protesting that

7 they will suffer and that we'll be driving econoboxes. 

8 That has never, ever happened. We've got incredible 

9 fuel economy, huge trucks, unbelievable MPG -- I mean, 

10 horsepower in our vehicles. And I think it's time that 

11 we get on with this and get it over with, make these 

12 rules and institute them. 

13 MR. TAMM: Thank you for your comments. Mr. 

14 Cooke. 

15 MR. COOKE: Thank you. My name is Dave Cooke. 

16 I'm a vehicles analyst with the Union of Concerned 

17 Scientists. The Union of Concerned Scientists is the 

18 Nation's leading science-based non-profit putting 

19 rigorous, independent science to work to solve our 

20 planet's most pressing problems. On behalf of UCS'

21 more than 450,000 supporters and network of nearly 

22 17,000 scientists, engineers, and public health 
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1 professionals, I’d like to thank EPA and NHTSA for 

2 their continued efforts to reduce fuel use by and 

3 global warming emissions from heavy duty trucks. 

4 These vehicles are responsible for a significant 

5 and growing fraction of fuel use and global warming

6 emissions. Left unchecked, they would undermine 

7 efforts throughout sectors to reduce fossil fuel use 

8 and its impact on the environment. This proposal 

9 provides an opportunity to improve upon the first phase 

10 of fuel economy and emissions regulations in this 

11 sector to continue to reduce the impact of this 

12 critical part of the economy. 

13 UCS has provided input throughout this rulemaking 

14 process, and we will continue to do so to ensure that 

15 these regulations are based on the best available 

16 science. Our analysis of the technologies that could 

17 be cost-effectively applied over the next decade 

18 indicates that the average fuel consumption from new 

19 trucks in 2025 could be reduced by 40 percent compared 

20 to trucks in 2010. 

21 The agencies' proposal of a 36 percent improvement 

22 by 2027 falls well short of what this analysis 
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1 indicates is possible. While EPA and NHTSA have 

2 certainly put forth a tremendous effort to write a rule 

3 based on up-to-date data, there are nonetheless still 

4 many aspects of the rule that should be improved. 

5 First and foremost, waiting until 2027 to fully 

6 implement the level of stringency that the agencies

7 have proposed is unnecessary. There is ample evidence 

8 that the technologies needed to comply with the 

9 stringency in the proposed alternative are either in 

10 the marketplace now or could be well before 2024. The 

11 public/private Super Truck Partnership and independent 

12 organizations like the National Academies' National

13 Research Council and the Southwest Research Institute, 

14 as well as discussions with both suppliers and 

15 manufacturers, have all supported our target of 40 

16 percent by 2025. 

17 Based on this analysis, recommend that the 

18 agencies accept alternative four, which would end in 

19 2024, as this path is much more consistent with the

20 trajectory of the industry to date and what 

21 manufacturers are capable of achieving. The agencies 

22 should not extend the timeline of the rule out to 2027, 
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1 2029 without using this additional lead time to 

2 increase the technology adoption and improve technology 

3 effectiveness significantly beyond what is currently in 

4 the proposed alternative. 

5 There are also specific areas where we believe the 

6 rule does not reflect the technology already 

7 anticipated over the coming decade. Most notably, the 

8 agencies have left significant improvements on the 

9 table for Class 8 tractor engines. The 4.2 percent

10 improvement in efficiency over a 10-year span is 

11 dramatically lower than the pace of improvements 

12 already achieved by manufacturers under the Phase 1

13 standards, and it does not reflect the level of 

14 improvement already being achieved in manufacturers' 

15 R&D projects. 

16 This has resulted in extremely conservative engine 

17 standard, one which is roughly two to three times lower 

18 than what could be accomplished by 2027. While the

19 engine test cycle has been improved to more accurately 

20 reflect the real world duty cycle of these engines, the 

21 engine standard itself significantly undermines the

22 real world savings that should be expected from tractor 
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1 trailers in the timeframe of this rule. 

2 Another area of the proposed standards that needs 

3 further adjustment are the regulatory targets for 

4 vocational vehicles. The agencies have improved their 

5 characterization of this sector by more accurately 

6 capturing the diverse duty cycles of these vehicles. 

7 They have also made powertrain testing an integral part 

8 of the regulation, which will help capture the improved 

9 efficiency of a better integrated engine and 

10 transmission. 

11 And last, the agencies have created a new pathway 

12 for secondary manufacturers to participate in the 

13 regulations through the delegated assembly provision, 

14 which will increase the flexibility for both primary 

15 and secondary manufacturers, including the small 

16 innovative manufacturers already selling vocational

17 hybrids today. 

18 Despite these improvements to the vocational 

19 vehicle framework, the proposed target does not reflect 

20 the full range of improvements available to these 

21 vehicles. The agencies have underestimated the fuel 

22 reduction potential of both conventional technologies, 
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1 like advanced transmissions and aerodynamic devices, 

2 and more advanced technologies, like hybrid and 

3 electric vehicles. 

4 This has resulted in a vocational vehicle standard 

5 that is significantly weaker than what can be achieved 

6 by 2027. Such a standard will not help drive 

7 technology investment, nor will it expand the offering 

8 of efficient vehicles for the fleets that need them. 

9 As in the case of tractor engines, the agencies appear 

10 to be lagging what the industry is already on track to 

11 accomplish. 

12 There are many other areas in which UCS believes 

13 the rule can be improved, including trailer 

14 aerodynamics, its treatment of natural gas, and its

15 assessment of gasoline engines for pickup trucks and 

16 vocational vehicles. Achieving a 40 percent 

17 improvement by 2025 would save an additional 200,000 

18 barrels of oil per day in 2035 compared to the proposed 

19 rule. It would also bend the curve on emissions below 

20 today's levels in spite of future increases in goods 

21 movement by a truck. That is the level of advancement 

22 we would expect this regulation to achieve. 
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1 We will continue to engage with the agencies to 

2 provide further data to strengthen the rule and ensure 

3 that we can achieve the maximum technology feasible, 

4 cost-effective reductions in this sector. Thank you. 

5 MR. TAMM: Okay. Thank you, Mr. Cooke. Does the 

6 panel have any questions for the -- 

7 MR. GRUNDLER: Thank you, Mr. Chairman. Mr. 

8 Oshnock, you said something interesting to me. You

9 said that in your current products in the light duty 

10 truck segment, cylinder deactivation and cooled EGR, 

11 you said this is in place in today's vehicles, making 

12 these technologies unavailable for Phase 2. Can you 

13 explain that, please? 

14 MR. OSHNOCK: They're in the heavy duty segment. 

15 If I said "light duty," I misspoke. We have them on 

16 our vehicles today. They're not gasoline engines. 

17 MR. GRUNDLER: 2Bs and 3s. 

18 MR. OSHNOCK: Yes. 

19 MR. GRUNDLER: Okay. Thank you for clarifying

20 that. I, again, want to thank the moms and daughters 

21 for taking the time to come here. I know you're not 

22 paid to present your testimony, and so it makes it even 
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1 more meaningful. 

2 So for both the Sierra Club and UCS, it'll be very 

3 helpful to us if you could provide any data that we

4 might've missed or new analysis that you've done to

5 support your view that the standards could be 

6 strengthened by two to three times, particularly for 

7 the engine standards. So I’d be eager to see more 

8 information on that. 

9 And, Mr. Cooke, you said that the -- while we 

10 improved the test procedures, did I hear you say that 

11 you think that the new procedures undermine real world 

12 improvements? Did I get that right? Can you explain 

13 that? 

14 MR. COOKE: So what I said was that -- well, I can 

15 probably quote it -- was that the weak -- that the test 

16 procedure itself has been improved, but the engine 

17 standard being so weak, that engine is used across the 

18 tractor trailer sector. And so, you base the 

19 stringency of tractor trailers, the vehicles 

20 themselves, and what read reductions they could achieve 

21 in this timeframe based on a weak engine performance. 

22 And so, that leads to a weak tractor trailer standard. 
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1 That's what I meant. 

2 MR. GRUNDLER: Okay. If you could elaborate on 

3 that in your comments. 

4 MR. COOKE: Absolutely. I will be happy to 

5 provide -- 

6 MR. GRUNDLER: It would be good for us to 

7 understand that. 

8 MR. COOKE: -- further data in our written 

9 comments. 

10 MR. SILVERMAN: Yeah, I’d elaborate on what Chris 

11 just said, that we are certainly eager to hear your

12 comments, but saying that technology is available in 

13 the marketplace now does not do it. We will need to 

14 know penetration rates, what it will cost, needed lead 

15 time, how that relates to manufacturers' design cycles. 

16 We'll need -- you know -- 

17 MR. COOKE: Yeah, absolutely. 

18 MR. SILVERMAN: We're very happy to listen, but 

19 that's the nature of the -- what we need to be told to 

20 understand. 

21 MR. COOKE: Absolutely. I mean, EPA and NHTSA did 

22 an exceptional amount of research, and there's a lot of 
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1 technical information in the rule. 

2 MR. SILVERMAN: And we'd like to think it's quite 

3 transparent and can be spoken to in the dialogue. 

4 MR. COOKE: Yeah, and we will -- we'll try to as 

5 much as possible speak EPA and NHTSA's language to 

6 address the specific shortfalls that we see in the 

7 rule. 

8 MR. SILVERMAN: Great. And I did want to say one 

9 more thing, not a question, but to Ms. Nichols and to 

10 the others who spoke about ozone. This rule is not

11 directed per se at ozone. The action that EPA takes 

12 that most influences ozone are the ambient standards. 

13 There's a pending proposal to decrease the level of the 

14 ambient standard down to a level between 65 and 70. 

15 We'll take final action on that one way or another on 

16 October 1st, so you should continue to watch what 

17 happens there. 

18 MR. TAMM: Okay. I think that's it for questions. 

19 So thank you very much, panel number two. And we'd 

20 invite panel number three to please come forward. Just 

21 as a note, too, after panel three is complete, then we 

22 will take a 15-minute break I believe it is. Yeah, 15-
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1 minute break. 

2 MR. GRUNDLER: Welcome, panel three. First up is 

3 Erin Roth from Wabash Trailers. Welcome. Thank you 

4 for coming. 

5 MS. ROTH: Thank you for having us here today. My 

6 colleague, Jamie Scarcelli, whom all of you are 

7 familiar with from previous discussions, was unable to 

8 be here today, so I'm here in his stead. But he sends 

9 his regards. 

10 Wabash National Corporation thanks the EPA and

11 NHTSA for allowing the allowing to comment on the joint 

12 proposed rulemaking Phase 2 greenhouse gas emissions 

13 standards and fuel efficiency standards for medium and 

14 heavy duty engines and vehicles. In addition to this 

15 testimony, we do intend to submit formal written 

16 comments with more detail for many of the things that I 

17 highlight today. 

18 Wabash National is a publicly-traded, diversified 

19 manufacturer headquartered in Lafayette, Indiana, and 

20 it's North America's leading producer of semi-trailers, 

21 having shipped more than 57,000 trailers in 2014, and 

22 an expectation to ship an even greater number in 2015. 
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1 With today's just in time environment, semi-trailers 

2 are vital to keeping the U.S. economy moving, and they 

3 deliver nearly 70 percent of all freight tonnage. 

4 Wabash National continuously seeks innovative 

5 solutions to improve fuel efficiency on trailers and 

6 lower operating costs for our customers. We support 

7 the objectives the EPA and NHTSA's Phase 2 proposal, 

8 and agree that sensibly reducing greenhouse gas 

9 emissions through fuel efficiency solutions is a good 

10 thing. Not only are sensible fuel efficiency solutions 

11 good for our air quality, but they help to conserve our 

12 fuel resources and have the potential to contribute to 

13 the decrease and the cost of freight transportation by 

14 creating greater overall freight efficiency. 

15 Freight efficiency is essentially hauling as much 

16 freight as possible at the lowest total cost. Fuel

17 efficiency is just one of the many inputs into the 

18 overall freight efficiency equation. Other 

19 considerations include road congestion and travel 

20 speed, total cube space and freight capacity, vehicle 

21 durability and safety, and driver behavior. Thus, to 

22 achieve overall improvements in freight efficiency,
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1 consideration should be given to not only programs 

2 encouraging the improvement of fuel efficiency, but

3 also to complementary programs and funding that seek to 

4 maintain and approve state and Federal highway systems, 

5 to maximize the freight capacity hauled on any one 

6 tractor trailer load, for example, the measures that 

7 allow for pulling twin 33 semi-trailers on Federal 

8 highways, and that further enhance the safety and 

9 durability of semi-trailers. 

10 The success of any of these programs, including 

11 these Phase 2 proposed rules, will depend, however, on 

12 adopting easy to implement policies that the complexity 

13 of the truck industry and the need for flexible 

14 solutions. And so, Wabash National urges the EPA and 

15 NHTSA to continue to address the following three 

16 concerns in promulgating a final rulemaking. 

17 First, the trailer manufacturer actually has very 

18 little leverage in determining what components are and 

19 are not included in a specific trailer. Contrary to 

20 popular belief, a semi-trailer is much more than just a 

21 box on wheels. Most trailers are designed for a 

22 specific freight application and are custom built for 
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1 each customer. Additionally, trailers are federally 

2 regulated by length, width, and height, so any 

3 innovations to improve freight capacity or fuel 

4 efficiency must also comply with these very restrictive 

5 Federal regulations. 

6 As a result of these regulations, today's 

7 solutions for improving fuel efficiency rely on devices 

8 that are attached to the trailers. Our customers do 

9 not simply accept the addition of these devices and the 

10 resulting additional costs without proof that they will 

11 definitely result in greater overall freight efficiency 

12 for their operations. 

13 Two, not all trailer types or freight carriers

14 will benefit from adopting fuel efficiency 

15 technologies. For example, tank trailers, flatbed 

16 trailers, and other specialty trailer types will not 

17 necessarily see benefits from the addition of 

18 aerodynamic devices, and for that, Wabash supports the 

19 EPA and NHTSA decision to exempt these trailers from 

20 aero requirements. 

21 In addition, even some fleets operating nothing 

22 but van semi-trailers will not see benefits from the 
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1 adoption of aerodynamic devices. This is because these 

2 types of trailers and fleets might operate in different 

3 duty cycles created by variations in operating 

4 locations and geographies, they may haul locally or

5 regionally, and infrequently reach highway speeds, 

6 which is where aerodynamic devices provide payback. 

7 And they may have unique freight hauling requirements 

8 or operate off road for portions of the time. 

9 The reality is some fleets and some trailer types 

10 simply will never demonstrate fuel savings through the 

11 use of aerodynamic devices. Thus, sensible final 

12 regulations should include exemptions for particular 

13 types of trailers or fleets whether through a fleet

14 exception approval process or by including an extensive 

15 list of trailer characteristics that would define an 

16 aerodynamic exemption. 

17 Three, incentivizing early adoption of fuel 

18 efficiency devices will be key. With the Federal 

19 regulation of the height, length, and weight of our

20 trailers, our solutions and our ability to comply with 

21 these regulations as a manufacturer rely on our 

22 customers accepting the additional of aerodynamic 
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1 devices to the frame of a trailer. If manufacturers 

2 are to be successful in influencing their customers to 

3 accept the inclusion of aerodynamic devices on new 

4 trailers, the regulations and the complementary 

5 regulations or legislation should not create 

6 disincentives for compliance. 

7 Thus, we urge the EPA, NHTSA, other agencies, and 

8 Congress to support legislation and the adoption of

9 rules that would exempt the cost of devices intended to 

10 improve fuel efficiency from Federal excise taxes, 

11 exempt the weight of devices intended to improve fuel 

12 efficiency from the Federal freight weight limits, and 

13 minimize the time, cost, and complexity of complying 

14 with the reporting obligations under the Phase 2 

15 rulemaking. 

16 While we would prefer that compliance be voluntary 

17 based on our industry's history of proactive 

18 introduction and adoption of aerodynamic and weight

19 saving innovations, and request the consideration of 

20 this fact, we acknowledge that there will be a trailer 

21 requirement. And absent a voluntary program, required 

22 adoption is preferred over an unmanageable averaging 
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1 compliance approach. 

2 As a technology leader in the semi-trailer 

3 industry, Wabash National welcomes any technology that 

4 assists our customers in improving overall freight 

5 efficiency. We support the goal of improving overall 

6 fuel efficiency, and welcoming -- and welcome 

7 continuing to work together -- fleets, manufacturers, 

8 suppliers, and regulators -- to develop holistic, 

9 practical solutions that will benefit stakeholders.

10 Thank you. 

11 MR. GRUNDLER: Thank you. Mr. Nelson, welcome. 

12 MR. NELSON: My name is Dennis R. Nelson, and my 

13 mailing address is P.O. Box 4453, Chicago, Illinois, 

14 60680-4453. My email address is 

15 dennisnelson987@yahoo.com. I am one of the original 

16 modern environmental energy activists ever since around 

17 the first Earth Day, Wednesday, April 22nd, 1970. I 

18 have a bachelor of science, BS degree, in biology 

19 environmental studies from Dana College, Blair, 

20 Nebraska. I'm a qualified energy environmental 

21 researcher, writer, speaker, and organizer. 

22 More than 45 years ago, our climate problem was 
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1 called the greenhouse effect. Nowadays I prefer to

2 call our climate crisis, the more appropriately 

3 accurate phrase is human caused climate disruption, or 

4 human made disruptive climate change. Unfortunately, 

5 we have not taken all the necessary actions fast enough 

6 to really deal with human-induced climate disruption, 

7 and the climate clock is ticking. There is a sense of 

8 immediate urgency inherently built into our current

9 situation, which requires that we do much more of the 

10 right things at a quicker pace. 

11 First off, I will offer my congratulations. Thank 

12 you for proposing the standards to make newer heavy

13 duty vehicles more fuel efficient in the first place. 

14 Secondly, I will offer my constructive criticism for 

15 improvement. The heavy duty vehicle fuel economy and 

16 carbon emissions standards should be made even stronger 

17 in order to achieve about 40 percent in fuel savings by 

18 2025. This would use cost-effective technologies that 

19 are now being deployed or demonstrated. An additional 

20 40 million metric tons of climate disrupting pollution 

21 would be avoided each year by 2035, which would be the 

22 equivalent of closing down around 12 coal-fired 
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1 stations. 

2 Another great thing about finalizing even tougher 

3 fuel economy standards for newer tractor trailers, 

4 vocational vehicles, and heavy duty pickup trucks and 

5 cargo vans is that they comprise a no regrets 

6 transportation energy efficiency strategy. Besides

7 promoting climate protection, they will also have other 

8 positive benefits, like cutting our oil consumption by 

9 an additional 200,000 barrels each day in 2035; 

10 reducing hazardous air pollutants from idling trucks 

11 and operating oil refineries, saving the average 

12 tractor trailer driver roughly $30,000 annually in fuel 

13 costs in 2025; reducing the expenses for the owners of 

14 truck fleets; and driving -- pun intended -- the green 

15 energy innovation for inherently cleaner heavy duty

16 vehicles. 

17 In conclusion, taking my advice and strengthening 

18 the final heavy duty vehicle economy and carbon 

19 emissions standards even more will improve our public 

20 health, ecological health, economic well-being, and

21 energy security. That concludes my testimony. Thank 

22 you. 
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1 MR. GRUNDLER: Thank you very much. Mr. Kubsh, 

2 proceed. 

3 MR. KUBSH: Good morning. 

4 MR. GRUNDLER: Good morning. 

5 MR. KUBSH: My name is Joe Kubsh. I'm the 

6 executive director of the Manufacturers of Emissions 

7 Controls Association. MECA is pleased to provide 

8 comments and support of the proposed rulemaking to 

9 establish medium and heavy duty greenhouse gas 

10 emissions standards for model years 2018 and beyond. 

11 We believe an opportunity exists to continue to reduce 

12 greenhouse gas emissions and improve fuel economy from 

13 these medium and heavy duty engines and vehicles by

14 applying the fundamental regulatory structure that has 

15 been effective under the first phase of these 

16 standards. 

17 MECA is a non-profit association of the world's 

18 leading manufacturers of emission control technology 

19 from mobile sources. Our members have more than 40

20 years of experience and a proven track record in 

21 developing and manufacturing emission control and 

22 efficiency technologies for a wide variety of mobile 
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1 sources. Now that regulated pollutants have been 

2 expanded to include CO2, the portfolio of products 

3 offered by our members has expanded to technologies

4 that impact combustion efficiency and improve the 

5 overall CO2 emissions of the powertrain. 

6 The mobile source emission control industry has 

7 generated hundreds of billions of dollars in U.S. 

8 economic activity since 1975 and supports more than

9 65,000 jobs in the U.S., mostly in product development 

10 and manufacturing. This proposal -- these Phase 2 

11 proposals on emissions and efficiency standards will 

12 provide additional support for the continued 

13 development of a thriving U.S. industry focused on a 

14 wide range of technologies that can reduce vehicle 

15 emissions and improve fuel efficiency. 

16 I’d like to offer the following comments on 

17 specific aspects of the Phase 2 proposal. MECA 

18 strongly supports the continued use of separate engine 

19 and vehicle standards included in the Phase 2 proposal. 

20 This framework developed for the Phase 1 standards

21 ensures the continued important testing linkage between 

22 engine criteria and greenhouse gas emissions, and 
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1 ensures that manufacturers deliver durable, enforceable 

2 improvements to truck fuel efficiency. 

3 MECA believes that cost-effective technical 

4 solutions will be available to allow for the faster

5 2024 implementation timeline included in EPA's 

6 proposal. Manufacturers need this regulatory certainty 

7 to continue to make the needed investments on 

8 technologies that will deliver these reductions. 

9 MECA supports the proposal to lower the cap on

10 nitrous oxide emissions from 100- to 50-milligram per 

11 brake horse power hour. This tighter N2O cap will be 

12 challenging in the expected future of lower exhaust

13 temperatures associated with improved engine 

14 efficiencies, but manufacturers have a number of 

15 technical opportunities available to them to keep 

16 nitrous oxide emissions at low levels, including 

17 improved catalyst formulations, improved ammonia slip 

18 catalysts with high selectivity for nitrogen formation, 

19 and efficient urea dosing technologies. 

20 MECA supports the proposal to close the current 

21 emissions loophole on truck glider kits. The legacy of 

22 dirty diesel engines on America's roads needs to put in 
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1 our rearview mirror. All new trucks need to utilize 

2 the clean diesel engine options that have been 

3 available since 2010. MECA asks EPA to consider an

4 even earlier closing of this loophole instead of 

5 waiting until 2018 to get these dirty diesel options 

6 off the table. 

7 MECA also believes that future auxiliary power

8 unit particulate emissions should be controlled through 

9 the application of proven diesel particulate filter

10 technology to these small off road engines. There are 

11 already examples of small off road diesel engines 

12 engineered with filter solutions that include active 

13 regeneration. EPA should follow California's lead and 

14 implement policies for APU engines that force the 

15 application of cost-effective filter solutions on these 

16 engines. 

17 Finally, MECA believes that significant further 

18 reductions in NOx emissions from new heavy duty on road 

19 diesel engines beyond the 2010 highway requirements

20 will be possible through the combinations of more 

21 advanced diesel engines with evolutionary improvements 

22 to the growing suite of advanced diesel exhaust 
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1 emission control technologies that include higher cell 

2 density, low thermal mass substraits, improved SCR 

3 catalyst systems coded directly on filter substraits, 

4 and advanced oxidation catalysts that include passive 

5 NOx absorber capabilities. 

6 Clean diesel emission technologies have expanded 

7 and matured considerably since EPA finalized their 

8 heavy duty 2007, 2010 NOx emissions standards nearly 15 

9 years ago in late 2000. The application of SCR 

10 technology on diesel engines has allowed engine 

11 manufacturers to optimize diesel engines for both low 

12 NOx emissions and improved fuel efficiency. And we

13 believe that these optimizations can continue in the 

14 future to allow diesel engines to further reduce both 

15 CO2 and NOx emissions. 

16 Advanced diesel emission control technologies are 

17 currently being evaluated in a California-sponsored

18 test program with the results available by the end of 

19 next year. The emission reductions benefits achieved 

20 through the deployment of advanced diesel emission 

21 control technologies are focused on delivering NOx 

22 reductions under Council transient portions of the test 
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1 cycle, and to improving NOx emission performance in low 

2 temperature duty cycle operations. 

3 MECA asks EPA to initiate a rulemaking that will 

4 further reduce NOx emissions from heavy duty engines as 

5 soon as possible to allow manufacturers to work with 

6 their customers on delivering fully optimized future 

7 engines that deliver improved fuel efficiency and ultra 

8 low NOx emissions. 

9 Thank you for your time and attention. 

10 MR. GRUNDLER: Thank you, Joe. Mr. Rudnick, 

11 welcome. 

12 MR. RUDNICK: Good morning. My name is Matthew 

13 Rudnick. I am manager of Global Fuel Economy and 

14 Greenhouse Gas Policy at General Motors. I'm pleased 

15 to speak with you today regarding the EPA and NHTSA

16 Noticed of Proposed Rulemaking to address greenhouse 

17 gas and fuel efficiency for medium and heavy duty 

18 trucks. 

19 General Motors is a major manufacturer of these 

20 vehicles, and we want to thank NHTSA and EPA for 

21 providing the opportunity to comment on this 

22 regulation. We have been working closely with both
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1 Agencies, and will continue to do so in order to 

2 establish standards for this integral part of the 

3 American economy. GM supports the adoption of a 

4 national standard covering these vehicles, and it is 

5 paramount that it be consistent with some critical and 

6 foundational principles. 

7 First, it's imperative that NHTSA and EPA develop 

8 a harmonized approach that does not penalize both 

9 consumers and manufacturers in providing products that 

10 will continue to serve the purposes, functions, and

11 utility that are needed. General Motors is supportive 

12 of the approach used during Phase 1 of this initiative, 

13 and encourages the continued harmonization of the café 

14 and GHG regulations. By creating one national 

15 standard, we can best maximize resources to produce

16 clean and efficient vehicles, which better align with 

17 the emission reduction standards put in place. 

18 Second, the program must continue to recognize the 

19 unique functionality and utility needs of the trucking 

20 industry, and that we provide vehicles that preserve 

21 the performance integrity of these work trucks. 

22 Consumers value the payload and towing capabilities
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1 that these working vehicles offer, and the work factor2 based standards set by EPA and NHTSA should continue to 

3 align with the industry and business needs of this 

4 demographic. 

5 Third, we have been gaining valuable experience 

6 concerning the importance of flexibility mechanisms, 

7 contained in the light duty vehicle greenhouse gas and 

8 fuel efficiency regulations, and these lessons can be 

9 applied to the medium and heavy duty fleet. For 

10 example, the pre-defined and pre-approved list of 

11 mobile air conditioner greenhouse gas credits has 

12 incentivized a rapid improvement in the efficiency and 

13 leak integrity of light duty vehicle air conditioners. 

14 These incentives are now paving the way for an early 

15 transition to lower global warming air conditioner 

16 refrigerants as millions of new vehicles are being 

17 produced with the new refrigerants, many years in 

18 advance of any mandate to make the switch. 

19 The success of these air conditioner provisions 

20 led to the expansion of this approach in 2014 for the 

21 light duty fleet with the introduction of an expanded 

22 off cycle list of pre-assigned and pre-approved credits 
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1 for other technologies that reduce fuel usage and 

2 conditions not comprehended in the standard fuel 

3 economy test, such as colder weather, higher speeds, or 

4 extended idle times. All of these flexibility 

5 mechanisms that have been successful for light duty

6 trucks can be applied equally to the Class 2B and Class 

7 3 pickups and vans covered by this proposed regulation. 

8 We have also had favorable experience with the

9 extended carry forward time allowed in the light duty 

10 regulation, which has resulted in manufacturers 

11 achieving greater improvements sooner based on the 

12 understanding that they will not waste through 

13 expiration the surplus credits that they have earned 

14 through their early actions. This concept could also 

15 be applied to the medium and heavy duty segments. 

16 The agencies' proposed Class 2B-3 standards, which 

17 are based on Alternative 3 in the Notice of Proposed 

18 Rulemaking, will continue to drive innovation, and will 

19 drive General Motors to Invest in and refine new 

20 technologies that are both appreciated and optimized by 

21 American consumers. We cautiously support this path 

22 based on Alternative 3 for future emission reduction 
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1 standards. This path will challenge our product plan 

2 and drive considerable technology into our heavy duty 

3 trucks and vans. 

4 Finally, the program must attempt to minimize the 

5 potential for unintended consequences, especially for 

6 the consumer. The heavy duty fleet does not benefit 

7 from the years of data that have been collected and

8 analyzed for the light duty fleet. Indeed, 

9 comprehensive data for this private segment is only now 

10 being accumulated and analyzed for the 2014 model year, 

11 which is the first year of Phase 1 of the medium and 

12 heavy duty truck regulations. 

13 Year-end reports for 2014 were due to EPA by the 

14 end of March 2015, so this first year of comprehensive 

15 industry-wide data is still fairly new. This new data 

16 should be carefully evaluated and then compared to the 

17 estimates and assumptions that form the basis for both 

18 Phase 1 and the proposed Phase 2 of the heavy duty 

19 regulations. 

20 We will providing more extensive written comments 

21 to address the key details that fundamentally crop up 

22 with the implementation of any new program. We look 
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1 forward to working with NHTSA and EPA to ensure the

2 program created is national in scope and consistent

3 with these principles. Thank you. 

4 MR. GRUNDLER: Thank you very much, Matt. Mr.

5 Keefer, welcome. 

6 MR. KEEFER: Yeah, thank you for your time. My 

7 name is Bob Keefer. I'm with Terex Corporation, and we 

8 have basically four comments regarding the proposed

9 changes regarding what has been referred to broadly as 

10 gliders. 

11 Comment number one, page 40529 of the proposal

12 says that EPA requests comment on whether we should

13 allow larger manufacturers to produce some limited 

14 number of glider kits. Similarly, page 40295 says the 

15 Small Business Advocacy Review Panel recommends that 

16 EPA seek comment on how to design a small business 

17 vocational vehicle exemption by means of a custom 

18 chassis volume exemption and what sales volume would be 

19 an appropriate threshold. 

20 Therefore, Terex proposes that if the EPA sets

21 limits on the quantity of gliders produced, it should 

22 not be based solely on the number of employees the 
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1 glider manufacturer has, but should also be based on 

2 the number of on highway vehicles it produces similar 

3 to the way the off highway transition program for 

4 equipment manufacturers is set up. 

5 For example, Terex Corporation has approximately 

6 20,000 employees globally, but only approximately 220 

7 are involved in the manufacturer of gliders at one 

8 small facility located in Fort Wayne, Indiana. Should 

9 the proposed regulations continue unchanged, it would 

10 result in the redundancy of some 70 team members at the 

11 Fort Wayne facility. Therefore, Terex proposes if a 

12 company manufactured fewer than 1,000 on highway 

13 vehicles annually between calendar years 2010 and 2014, 

14 then it should be eligible for the same exemptions as a 

15 small manufacturer under the proposed 1037.635(b). 

16 Comment number two, the proposed definition number 

17 three of "glider kit" on page 40662 says that a "glider 

18 kit" means "any other new equipment that is intended to 

19 become a motor vehicle with a previously used engine, 

20 include a rebuilt or remanufactured engine." Terex

21 requests further clarification and/or a definition of 

22 "other new equipment." The intention of this request 
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1 is to eliminate confusion over whether certain new 

2 parts or assemblies that would be used to repair an

3 existing vehicle would be considered as "new equipment" 

4 by the EPA. 

5 Comment number three, page 40229 says that 

6 building a glider out of salvaged powertrain from 

7 vehicles destroyed in accidents is "an arguably 

8 legitimate purpose," and Terex agrees with the agencies 

9 on that. The proposed limitation on gliders doesn't 

10 distinguish between repaired vehicles and glider kits. 

11 Terex suggests that language be added that allows for 

12 a used powertrain to be installed onto a new chassis 

13 for the case of repairing a damaged vehicle, and not be 

14 subject to regulations that are newer than the original 

15 bill date of the damaged vehicle. 

16 And then my final comment number four is regarding 

17 page 40186. It says that six by six and eight by eight 

18 vehicle configurations are only manufactured for 

19 specialized vehicles that require extra traction for 

20 off road applications. They are very low volume sales, 

21 and their increased fuel consumption and CO2 emissions 

22 are not significant in comparison to the overall 
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1 reductions of the Phase 2 program. 

2 Therefore, Terex suggests that vehicles with six 

3 by six and eight by eight configurations must be added 

4 to the last of exemptions under the proposed 

5 1037.635(b) concerning glider kits. Because these 

6 vehicles operate off road, they are far more 

7 susceptible to wear and tear type frame damage that is 

8 premature compared to the engines that were designed to 

9 operate for a million miles. For this reason, 

10 glidering six by six and eight by eight vehicles is and 

11 has always been common industry practice, even before 

12 the arrival of after treatment systems on diesel 

13 engines. 

14 Thank you. 

15 MR. GRUNDLER: Thank you, and I appreciate you

16 supplying the page numbers for us to refer to. 

17 MR. KEEFER: Yes. 

18 MR. GRUNDLER: Ms. Gustafson, welcome. 

19 MS. GUSTAFSON: Yes. My name is Marcia Gustafson. 

20 I work with children and adolescents. I say that 

21 because I think you'll hear their voice in my little 

22 spiel. 
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1 I'm going to start this with an insult and then a 

2 compliment. Humans are probably not the most 

3 physically beautiful species on our planet, but we do 

4 have one special feature that can make us possibly 

5 outdistance the other species. It is our capacity to 

6 build a conscience, to not let self-interested lies

7 paralyze us. 

8 What a conscience can do is allow us to go 

9 backwards and forwards, weigh in on our actions and

10 decisions, and ultimately live comfortably with our

11 internal selves for a lifetime. But a conscience must 

12 be cultivated or it will become an empty shell. 

13 Pretense, denial of truth, and selfishness must be 

14 judged against knowledge, courage, and generosity. 

15 You don't need to fight in a war to save your 

16 country, but you do need to be brave enough to stand up 

17 to deniers and declare "enough of your self-interests." 

18 As a species, we can only survive when truth committed 

19 to action becomes our way of life. It's our planet, 

20 and we need to stand up for it now. That's it. 

21 MR. GRUNDLER: Thank you very much for reminding 

22 us all why we're doing this work. Ms. Rondeau, 
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1 welcome. 

2 VICE ADMIRAL RONDEAU: Good morning, and I thank 

3 you for the opportunity to give this testimony in 

4 support of the rule. My name is Ann Rondeau. I'm a 

5 retired vice admiral in the U.S. Navy. I retired in 

6 2012, and frankly I've had two tours here in Illinois. 

7 One was I was the commander in charge of all of the 

8 recruit training up north of here in the Great Lakes, 

9 and as a three-star I was the deputy combatant 

10 commander down at Scott Air Force Base for the United 

11 States Transportation Command. And that particular

12 command is a joint functional commander that supports 

13 all the distribution and transportation needs of the 

14 Department of Defense, the military services, the 

15 defense agencies, and, frankly, most other of the 

16 United States government agencies around the world. In 

17 other words, a truck or convoy did not move without my 

18 command knowing that. And so, I come to you with that 

19 personal experience. 

20 I also, though, come as the voice to the Military 

21 Advisory Board. This is a board comprised of retired 

22 three- and four-star admirals and generals who have
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1 spent over a decade studying the science, the data, and 

2 the policies with regard to environmental issues and 

3 their impact upon national security. We look at 

4 everything from climate change, to the economy, to fuel 

5 efficiencies, and to those kinds of things. 

6 So I come as a voice for the board and not just 

7 mine, but I come with mine with regard to the lens of 

8 experiences that I bring to this issue. And I'm driven 

9 by the fact that there's a battlefield voice to this 

10 issue. Since World War I, we have been a mechanized, 

11 motorized military. We have been -- we have been 

12 geniuses at developing technology innovation to be more 

13 mobile, more agile, more adaptive, and, frankly, more 

14 maneuverable. But the one thing that has not changed 

15 since World War I is the dependence on oil and on 

16 fossil fuels to get from one place to another. 

17 Matter of fact, I would say to you that fuel 

18 efficiency is a primary issue for the U.S. military. 

19 The Army even has an Army Environmental Policy 

20 Institute to try to figure this out. This is not just 

21 a fleeting imperative; it is a national imperative need 

22 and requirement and imperative. 
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1 For us, fuel efficiencies for things like 

2 generators and heavy duty trucks is really important to 

3 our ability to be operationally and tactically 

4 effective. If we have more fuel efficiency, we have 

5 better operational impact. If we have more fuel 

6 efficiency, we'll have fewer convoys and, frankly, 

7 fewer trucks. And more to the point, with fuel 

8 efficiency we will have fewer lives lost. 

9 In 2009, the U.S. Army did a study about the issue 

10 of the transportation aspects of the U.S. Army, and

11 they looked at the year 2007 in Afghanistan. And 

12 through the -- through the analysis which they had 

13 conducted came to the fact that one of every 24 convoys 

14 was attacked in Afghanistan causing the death or 

15 maiming of soldiers, sailors, marines, airmen, and of 

16 civilians. So there's a tactical and operational need 

17 here and an imperative to make this a more efficient 

18 set of rules that would lead then to better and more 

19 efficient vehicles. 

20 There's also the cost. When we talk about costs 

21 in the military for oil and gas and fossil fuels, it is 

22 not just the cost of the commodity. It's a fully 
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1 burdened cost, which is not only the price of the oil, 

2 the gas, it is also the entire life cycle cost to get 

3 the gas from point of sale to point of effect, from

4 point A to point B. This is an enormous cost to the 

5 taxpayer and to the United States military. 

6 So one is that a fuel efficient heavy duty 

7 vehicles, and engines, and everything that is heavy

8 duty is good for us tactically and operationally. It's 

9 good for us on cost. And the fourth is that it is of 

10 strategic importance to the national security of this 

11 country. 

12 I'll stop there to end with one last thought. The 

13 U.S. has had enormous ability to transfer civilian 

14 technology to military purposes and vice versa. We

15 would say to you the board is that the time and 

16 opportunity and the genius of America's now support

17 this rule, and make us a safer and better nation. 

18 Thank you very much. 

19 MR. GRUNDLER: Thank you so much, Admiral. Thank 

20 you for lending your voice as well as for your service 

21 to your country. I've got one question for Ms. Roth. 

22 Your testimony -- your testimony noted that your firm 
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1 is opposed to a compliance averaging approach. 

2 Typically we include these provisions because firms

3 find it useful to transition to better products, more 

4 efficient products, and allows them to fully amortize 

5 their previous products. Can you explain, you know, 

6 why this doesn't work for your business? 

7 MS. ROTH: Sure. So in the trailer industry, we 

8 are not building typically what I would call stock 

9 trailers or, say, building years in advance to then

10 sell out. It's a custom built industry that are built 

11 on specs that are set by particular customers. So 

12 while in theory averaging would allow us to, you know, 

13 potentially under build or under comply with the 

14 regulation by over complying with other customers, the 

15 reality is in any given year, since we are captive to 

16 whatever the specifications are of that particular 

17 customer, that mix of that particular year, we have

18 very little control over how much compliance we can

19 really with regard to this regulation on any given 

20 order. 

21 So what we'll be left with is if we have a mix in 

22 a particular year of several customers who are 
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1 insisting that because of whatever their application is 

2 they don't want to accept these devices, we will either 

3 lose those orders to some other competitor, who maybe 

4 because of their mix with their customers that year, 

5 can build it into an averaging scenario, or in a very 

6 low margin industry like the trailer industry, we're 

7 going to eat the cost of the aero devices that we would 

8 stick on that customers wouldn't necessarily want in 

9 the first place. 

10 If we were a more, what I would call, stock 

11 standard industry, more like the auto industry that

12 produces a certain amount of cars -- they're pushed out 

13 there and consumers just buy them -- this would add -- 

14 this would be perfect to put averaging into the mix. 

15 But since it is custom built and it is designated to us 

16 what we are supposed to build by the customers and we 

17 don’t have the flexibility there, this doesn't really 

18 help us in that scenario. 

19 MR. GRUNDLER: I understand. That's helpful. If 

20 you could be sure to include this in your written 

21 comments so that we can fully understand it, that would 

22 be a big help. Thank you. 
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1 MS. ROTH: We will. Thank you. 

2 MR. TAMM: I’d like to add one more question, and 

3 that is I think your testimony alluded to for specific 

4 type use, trailers or certain fleets potentially having 

5 exemptions for those. Do you have some specific 

6 proposals on what the various descriptions would be or 

7 definitions would be of what could be exempted? 

8 Certainly ideas on that sort that you might have would 

9 be -- would be valuable. 

10 MS. ROTH: We will certainly elaborate on that

11 within our formal comments that we'll submit, but for 

12 purposes to respond to you today, we think some of the 

13 devices that you have noted in the rule as work devices 

14 that would exempt or make a partial aero trailer is a 

15 very good start. We are attempting to identify some 

16 other characteristics that might also be added to that 

17 list. 

18 We are also in favor, though, of an approach very 

19 similar to what CARB is using that would allow the 

20 fleets to provide information to the manufacturers, and 

21 then the manufacturers as part of the compliance 

22 process being able to submit information and criteria 
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1 that would exempt that a particular fleet from this

2 regulation if they meet certain criteria, again, 

3 similar to what CARB has set out in California. 

4 MR. TAMM: Okay. Thank you. 

5 MS. ROTH: Thank you. 

6 MR. SILVERMAN: To Mr. Keefer, we had a previous 

7 witness who suggested that there should be less lead 

8 time to apply engine and vehicle standards to glider 

9 kits. Do you have any reaction to that? 

10 MR. KEEFER: I would say officially no, but I 

11 think more generally is this confusion over the 

12 definition of what a glider kit is and whether we're 

13 repairing a truck or building a new glider. So I 

14 think, you know, we have to first clarify those terms, 

15 you know, before we can discuss that, I think. 

16 MR. SILVERMAN: Thank you. 

17 MR. GRUNDLER: Okay. We're going to take a short 

18 break now. We will reconvene at 11:30. Thank you very 

19 much. 

20 (Break.) 

21 MR. GRUNDLER: Before we get started with panel 

22 four, I want to recognize we have in the audience today 
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1 the architect of the Phase 1 rules. Chet France has 

2 joined us. Welcome, Chet, wherever you are. So if you 

3 didn't like Phase 1, go to find Chet. He's somewhere 

4 in the back of the room. And we're going to try to get 

5 him on one of the subsequent panels. 

6 MR. TAMM: And for those who may have joined since 

7 we walked through some opening remarks, we're basically 

8 inviting the panel who will come in after the panel

9 that's currently up front to sit on seats on the side 

10 here. So I'll read off who is in the upcoming panel as 

11 well. And for all of the people who are commenting

12 today, we've got a guide here, a timer guide, which it 

13 basically it's set for five minutes. So the red light 

14 will come on at five minutes. There will be a green 

15 light for the first four minutes, and a yellow light to 

16 let you know when there's one minute left. 

17 So the panel individuals, if we could ask to go 

18 over to the staging area: Michael Zurakov, Rashunna 

19 Delaney, Patti Perry, Karen Fort, Robert Natkin, Tony 

20 Fuller, and Jan Franklin -- Frankel. Sorry. So if you 

21 could proceed to the -- there's seats over here. If 

22 you could proceed to that area, then that'll -- there's 
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1 a little bit of prep work with getting cards together. 

2 It helps to expedite the panels. 

3 So with that, Mr. Schaeffer, if you're ready, 

4 please. 

5 MR. SCHAEFER: Yep, thank you very much. Good

6 morning. I'm Allen Schaeffer, executive director of 

7 the Diesel Technology Forum. We are a non-profit 

8 educational organization that represents the leaders in 

9 clean diesel technology, including engine vehicle and 

10 equipment manufacturers and affiliated organizations. 

11 Thank you for the chance to appear today and comment on 

12 these proposed rules. 

13 Today manufacturers of commercial trucks, engines, 

14 and their components produce the cleanest, safest, and 

15 most fuel efficient technology in the world. For all 

16 parties, the challenge of further increasing fuel 

17 efficiency while maintaining or improving environmental 

18 safety and productivity of commercial vehicles is as 

19 important as it is complex. 

20 Diesel engines are the prime mover of the global 

21 economy and the primary power plant for the wide range 

22 of commercial trucks under discussion today. We hope 
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1 that the outcome of these proceedings sets the stage to 

2 build on the success already accomplished in achieving 

3 near zero emissions with today's new clean diesel 

4 technology with continued innovation in technology and 

5 products that are highly desired by customers. 

6 We'd like to focus our comments today on three

7 areas: first, the role of diesel engines in commercial 

8 vehicles and the transformation to clean diesel 

9 technologies; secondly, the clean air fuel saving and 

10 other benefits accruing; and third, a framework for

11 continued success. 

12 First, new clean diesel technology will contribute 

13 to further efficiency gains and continue to be the 

14 primary power train for commercial vehicles. Advances 

15 in diesel engines are a key part of this Phase 2 

16 rulemaking, and we fully anticipate they will continue 

17 to contribute to that overall efficiency gain desired 

18 by the rule. Diesel is going to continue to be the

19 power plant of choice because it offers an unmatched 

20 combination of power, increasing energy efficiency,

21 work capability, reliability, and now near zero 

22 emissions environmental performance, along with an 
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1 ability to utilize a variety of low carbon renewable 

2 diesel fuels. 

3 Since 2000, the leaders in clean diesel technology 

4 and EPA have worked together to establish a very 

5 successful framework of getting us to near zero 

6 emissions that are now 98 percent lower than they were 

7 at a previous time. In fact, earlier this year the

8 American Lung Association in its State of the Air 

9 report noted that clean diesel fleets are one of the 

10 two major reasons for the clean air progress observed 

11 nationwide in 2014. These new technology clean diesel 

12 engines are being widely embraced by customers as 

13 evidenced by the increasing penetration into the 

14 vehicle population. 

15 According to our analysis of state registration 

16 data, right now there's about 37 percent of all the

17 commercial trucks on the road are 2007 and newer, and 

18 about 22 percent, or roughly 1.9 million vehicles, are 

19 2010 and newer technology vehicles. And I'm happy to 

20 report that since we're here in Illinois, Illinois 

21 ranks number four nationwide for the percentage of new 

22 technology 2007 trucks on the road, and number five
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1 nationwide for the 2010 and newer vehicles. So here, 

2 that means 40 percent on the roads in Illinois today 

3 are 2007 and newer. 

4 Last year was a very strong year for the sector. 

5 Over 186,000 new medium duty trucks were sold, Class 4s 

6 through 7, along with 230,000 heavy duty Class 8 trucks 

7 sold. The overwhelming majority of these were powered 

8 by clean diesel with just a few thousand units powered 

9 by other fuels. By 2023, the Fuels Institute estimates 

10 that diesel engines will power between 95 and 97 

11 percent of all these vehicles despite the introduction 

12 of alternative fuels and powertrains, including all

13 electric fuel cell, and continue the reduction of 

14 natural gas commercial vehicles. 

15 Secondly, climate fuel savings and clean air 

16 benefits from new technology diesel engines are 

17 accruing today. In just the last four-year period from 

18 2010 to 2014, research that we've just completed shows 

19 that the technologies on the road today have already 

20 reduced by nine million tons of CO2 about 880 million 

21 gallons of diesel fuel. That's 21 million barrels of 

22 crude -- 1.45 million tons of NOx -- have already been 
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1 removed in the 2010 to 2014 timeframe. 

2 Those are equivalent to the carbon emissions 

3 generated annually from 2.4 coal-fired power plants

4 since clean power plants are subject to conversation 

5 this week. And the NOx emissions from 158 coal-fired 

6 power plants. So you can see we are already making

7 significant impacts in reducing carbon emissions and 

8 NOx. 

9 Regarding vehicle technologies and what's going to 

10 be happening in Phase 2, I’d like to say a few words 

11 about things that are not covered under this rule, the 

12 first being renewable diesel fuels. This rule focuses 

13 on vehicle and engine standards, but does not get into 

14 fuels. We believe that looking at the use of renewable 

15 diesel fuels in all diesel engines today can offer 

16 immediate benefits in reducing emissions of CO2 and

17 other pollutants. Just this week -- I'm sorry. Just 

18 this week, UPS announced that they plan to use 46 

19 million gallons of renewable diesel over the next three 

20 years. 

21 I’d also like to encourage that we think about

22 expanding the consideration beyond just making new 
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1 engines and vehicles cleaner and more efficient, and to 

2 looking at the existing population of trucks, and how 

3 they're operated, and encourage the introduction of new 

4 technology diesel engines. Finally, there's a 

5 framework for continued success. You're all familiar 

6 with this, and I think other commenters have touched on 

7 these: a national program, adequate lead time, neutral 

8 in terms of fuel standards, et cetera. 

9 In summary, we believe that advanced truck and

10 engine designs that reduce emissions will provide 

11 significant savings for truck owners and clean air 

12 benefits for everyone. The engine of the future may 

13 look and perform somewhat differently and may be 

14 burning different kinds of low carbon fuels. But in 

15 the end it will still be a diesel engine and an 

16 integral component of meeting the needs of a growing 

17 economy and a cleaner and more sustainable future. 

18 Thank you. 

19 MR. TAMM: Okay. Thank you for your comments. 

20 Mr. Chandler. 

21 MR. CHANDLER: Thank you. The Center for 

22 Neighborhood Technology appreciates the opportunity to 
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1 provide testimony this morning. The Center for 

2 Neighborhood Technology, CNT, we're a 40-year-old not3 for-profit organization, but we do projects that 

4 demonstrate and research environmentally beneficial new 

5 technologies and systems for businesses, and 

6 communities, and governments to operate in urban 

7 environments. 

8 We'd like to speak in support of the previous 

9 recommendation from the Union of Concerned Scientists 

10 that would recommend going to a standard that would

11 reach 40 percent reduction, improvement in fuel 

12 efficiency by 2024. And we'd like to present two basic 

13 reasons that might not have been -- might be overlooked 

14 by others as to why we think that this standard is 

15 appropriate. 

16 One reason is the fact that heavy duty trucks are 

17 now the leading -- the most rapidly growing source of 

18 mobile emissions in the country. We've seen a pattern 

19 since the recession in which car driving automobile VMT 

20 has been declining. It's flattened out in the last few 

21 years. It's now going into a slight decline. At the 

22 same time, truck use has been increasing more or less 
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1 in proportion to the rise in GNP. So as this pattern 

2 continues, what we can expect to see is a greater need 

3 to regulate the amount of emissions that's being 

4 generated by heavy trucks. 

5 The other reason that we think is significant is 

6 for lowering the emissions of heavy trucks is the 

7 impact that it has on other forms of economic 

8 development, particularly mode shift to rail, and the 

9 development of businesses, industrial and logistics

10 businesses, distribution businesses, around intermodal 

11 freight terminals. If we had the best possible methods 

12 of reducing emissions from trucks, we would still find 

13 it desirable to have a major mode shift in freight 

14 movement between -- from truck to rail. We're all 

15 familiar with the data for that, which indicates that 

16 depending on three to seven times more efficient per 

17 ton mile movement of freight when moving the freight by 

18 rail. 

19 And intermodal freight had made significant gains 

20 in reducing and generating savings through mode shift. 

21 The amount of volume of containers that's moving by 

22 intermodal has risen from a little than six million to 
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1 over 13 million just over the last 20-year period. And 

2 as this has happened, intermodal terminals have been 

3 built in 64 different regions and created thousands of 

4 jobs that have the basic advantage of lowering 

5 transportation costs for the manufacturing and 

6 distribution companies that are locating there. 

7 Today new technologies are making it possible to 

8 reduce the pollution that occurs from terminal 

9 operations and from rail operations. And we can talk 

10 about potential for zero emission ports, zero emission 

11 intermodal terminals despite the fact that the 

12 railroads still have a long way to go to improve their 

13 operations. 

14 But the major impediment to the development --

15 further development of businesses co-located with 

16 intermodal freight terminals is the amount of truck

17 traffic that's associated with those kinds of 

18 facilities. Because of the environmental risk involved 

19 in having several hundred, several thousand trucks a 

20 day coming to one location, this is serious impediment 

21 to locating these kinds of facilities in place where 

22 there's already an existing industrial base, places
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1 where workers can get to. 

2 And consequently, these facilities are often 

3 relocated in exurban locations, which creates a whole 

4 cascade of other problems, long interregional truck

5 trays, problems with people getting to work, longer

6 commutes for workers. And so, but, you know, sort of 

7 ironically, if we're going to reduce these risks and 

8 make it possible to have co-located businesses and 

9 terminals, we need to reduce the level of emissions

10 from trucks in a drastic manner. 

11 So, you know, along with these points, we'd just 

12 like to point out that as the standards are introduced, 

13 we recognize that the nature of the standards is the 

14 main subject of this discussion. So thank you for your 

15 time. Appreciate it. 

16 MR. TAMM: Okay. Thank you for your comments. 

17 Mr. Urbaszewski. 

18 MR. URBASZEWSKI: Thank you. Excellent 

19 pronunciation. Thank you for the opportunity to make a 

20 statement today. May name is Brian Urbaszewski, and I 

21 work for Respiratory Health Association founded in 1906 

22 in Chicago. We work to prevent lung disease and to
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1 promote lung health through research, advocacy, and

2 education. 

3 We're thankful for the immense progress made in 

4 cleaning up diesel engines in recent years largely due 

5 to EPA's actions. Huge cuts in tailpipe pollution from 

6 new heavy duty diesel vehicles and diesel equipment

7 have been achieved, and which are now largely 

8 delivering improved human health every year. 

9 Tailpipe derived particulate matter triggers 

10 asthma attacks and heart attacks, and drives increases 

11 in emergency room visits, and hospitalizations, and

12 premature deaths. Eliminating those emissions as well 

13 as slashing ozone forming and toxic air pollution has 

14 reduced health risks and, in fact, has saved lives. So 

15 thank you on behalf of the over one million people in 

16 Illinois living with lung disease. 

17 Yet even with cleaner new engines and our 

18 continued use of EPA and DOT funds to accelerate the 

19 cleanup of the emissions from long-lived diesel engines 

20 that pre-date EPA's stringent standards, new challenges 

21 have arisen. It's become increasingly clear that 

22 global warming is a health threat, particularly to 
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1 people living with lung disease. 

2 Increasing heat waves put people with limited lung 

3 capacity at higher risk of hospitalization and death. 

4 Longer, hotter summers extend the ozone smog season, 

5 and increases the likelihood of unhealthy air days,

6 cutting the gains we have made in reducing ozone 

7 precursors. More flooding means more displacement of 

8 medically vulnerable people and hinders access to 

9 medical care, and more allergenic pollen means greater 

10 risks for those with allergy-triggered asthma and 

11 misery for those who have allergies like hay fever.

12 Higher temps and greater droughts also increase 

13 the prevalence of wildfires, creating smoke plumes that 

14 travel hundreds of miles polluting the air where 

15 millions of people live. In fact, in 2011, a wildfire 

16 on the Canadian triggered air quality alerts here in 

17 Chicago. And last month, Canadian fires triggered 

18 unhealthy code red air quality alerts as far south as 

19 Missouri. The increasing effects of global warming are 

20 already having a direct impact on people's ability to 

21 breathe. It's putting vulnerable groups at risk, 

22 including babies, children, senior citizens, and those 
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1 that live with chronic lung and heart conditions. 

2 Every barrel of oil burned means more carbon 

3 dioxide in the atmosphere, further increasing global 

4 warming. Reducing fuel consumption through greater

5 efficiencies and through the development of non-fossil 

6 fuel technologies that eliminate carbon emissions are 

7 needed to address these health threats. For those 

8 reasons, we believe strong EPA greenhouse gas tailpipe 

9 standards are necessary. And while we strongly support 

10 the direction of proposed EPA climate rules for new

11 trucks, we also believe the proposed standards should 

12 be strengthened, and that EPA should increase its goal 

13 to achieve a 40 percent fuel savings by 2025. 

14 The agency can further increase the $37 billion in 

15 health and welfare benefits the proposed rule would

16 bring. The ability to gain additional reductions is 

17 there. The agency should go beyond its very 

18 conservative approach to capture additional fuel 

19 reductions, a strategy we believe will benefit public 

20 health for many years to come. 

21 Again, thank you for the time and the opportunity 

22 to speak on this issue today. 
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1 MR. TAMM: Okay. Thank you for your comments. 

2 Mr. Burger? 

3 MR. BURGER: Good morning. I'm Mark Burger, a

4 resident of Oak Park and former president of the 

5 Illinois Solar Energy Association. And I appreciate 

6 this opportunity to testify in favor of the U.S. EPA 

7 and DOT's proposed second phase reduction of carbon

8 pollution and oil use from heavy duty freight trucks. 

9 I live right by the Eisenhower Expressway, and

10 emissions from the constant flow of trucks reminds me 

11 of the fuel waste and health effects to my household 

12 and my neighbors. The proposed standards will result 

13 in significant pollution reduction and increase in 

14 health benefits, as my fellow supporters will testify. 

15 I want to emphasize the economic benefits that

16 improved truck fuel efficiency standards will bring. 

17 Improved fuel efficiency standards resulting in demand 

18 destruction are one of the best tools to reduce 

19 pollution and keep fuel prices affordable. The fuel 

20 efficiency standards of cars and light trucks has 

21 resulted in the present savings of about three to four 

22 million barrels a day in the U.S. 
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1 Had these standards not been in place, pollution 

2 from an additional billion or more barrels of petroleum 

3 a year would be in our atmosphere as well as higher

4 prices for gasoline and diesel. Adoption of improved 

5 truck efficiency standards is our best protection 

6 against future risk factors, higher costs, and 

7 pollution. 

8 There are five risk factors to fuel prices in the 

9 near and long term. First is possible global pricing 

10 of carbon emissions. At $25 to $50 per metric ton,

11 that can means adding $10 to $20 to the price of a 

12 barrel of oil, or up to 25 to 50 cents per gallon of 

13 fuel. The second global risk factor is a geopolitical 

14 event up to and including warfare that could disrupt or 

15 interrupt oil and gas shipments. The last one is 

16 declining rates of extraction by cost or available 

17 resources. 

18 For U.S. supply and pricing, there are two major 

19 risks to oil and gas prices and supply. First if the 

20 lifting of the ban on petroleum exports and development 

21 of robust infrastructure to facilitate shipment, 

22 especially for liquefied natural gas. The result will 
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1 likely be U.S. prices of oil and gas moving upward 

2 toward global market prices. 

3 At present there is only about a 10 percent spread 

4 between Brent and West Texas intermediate petroleum

5 prices. The greater risk, however, U.S. natural gas 

6 prices rising to European or Asian levels of two to

7 four times greater. The other risk factor is shale

8 extraction of petroleum and natural gas may be far more 

9 short-lived than traditional extraction. Combined with 

10 exports to higher priced markets puts the U.S. gasoline 

11 and diesel consumer at greater risk. It also 

12 neutralizes the premise that shifting heavy truck fuel 

13 from diesel to natural gas will be a cost saver without 

14 higher efficiency standards. 

15 So for these economic as well as environmental

16 reasons, I support and applaud the proposal by the EPA 

17 and DOT to improve our Nation's heavy truck fuel 

18 efficiency standards. Thank you. 

19 MR. TAMM: Thank you for your comments. Ms. 

20 Laraia? 

21 MR. LARAIA: My name is Mary Laraia, and I am from 

22 Chicago, Illinois. Thank you very much for giving us 
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1 all this opportunity to speak to you about the new 

2 proposed regulations. 

3 I'm a private citizen who has spent the bulk of 

4 her career in the banking industry specializing in bank 

5 compliance, and currently a bank director at Standard 

6 Bank and Trust Company in Illinois. And I do 

7 appreciate the need for creating and maintaining high 

8 quality, enforceable, and effective regulations. 

9 I was also the director of North American 

10 Sustainability for Bank ABM AMRO, and in that regard we 

11 specialized in providing banking solutions around toxic 

12 and contaminated properties, but also in figuring out 

13 how to finance the kind of changes that are being 

14 talked about today in making previously unfinanceable 

15 projects financeable, and, therefore, possible to 

16 achieve. I also watched the effect of climate change 

17 in a stint that I did as the deputy superintendent of 

18 the Forest Preserve District of Cook County, one of the 

19 largest and oldest private -- public urban land 

20 reserves in the country. 

21 But I came here today because I love vehicles of 

22 all kinds. I grew up in a happy truck-focused 
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1 household. My father's first business was a filling 

2 station that he ran with his brothers, and he soon 

3 thereafter ran an aftermarket vehicle supply company 

4 out of our garage at home. He serviced, loaded, 

5 unloaded, drove vans and trucks every day of his 

6 working life. I was married to a man who worked on a 

7 racing car team. I myself have driven high-performance 

8 vehicles my entire driving life. And just five months 

9 ago traded in my last one, albeit reluctantly, for a 

10 hybrid. 

11 My friends and I haul materials, people, animals, 

12 supplies around in large trucks and trailers for our 

13 vocations and avocations. And I hope we will always 

14 have these opportunities for moving ourselves and our 

15 supplies. And I think these regulations will help make 

16 that happen. I know we need to improve how all my 

17 favorite vehicles operate. 

18 I am deeply concerned about long-term energy 

19 independence. I do fear for national security and its 

20 relationship with oil and other petroleum products. I 

21 sometimes despair about the health problems for our

22 children ad for our elderly. And on a more personal 
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1 level I have suffered from asthma for decades 

2 corresponding roughly with the time that I moved from 

3 rural to an urban area. And it is quite possible that 

4 my father's untimely death when I was only 29 was due 

5 to his long and close exposure to petroleum products 

6 and the pollution in the Chicago area. But there's the 

7 magic. Every one of these issues will positively 

8 addressed upon implementation of these regulations, at 

9 least to some degree. 

10 I believe the proposed regulations are helpful and 

11 reasonable. I know from my experience in business that 

12 these improvements will actually save both oil and 

13 money as we go through the next decades. We are in the 

14 middle of the transportation industry here in Chicago, 

15 and I have watched, even though my own lifetime, as our 

16 air and water have become cleaner through regulations 

17 very much like the ones under review today. 

18 In my work -- in my work at the Forest Preserve, 

19 one of the highlights that I experienced was personally 

20 being able to see a female bald eagle and her fledgings 

21 for the first -- who were the first eagles born in Cook 

22 County in nearly 100 years. The pollution in our air 
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1 and water and, therefore, in the eagles' food supply 

2 did not allow female eagles to produce eggs that were 

3 not crushed when she sat on them. We can make these 

4 improvements, and that's why I hope these regulations 

5 will be not only adopted, but strengthened. We're not 

6 finished with this work, and we're doing actually 

7 rather well at it thanks to people like you who work at 

8 it day after day after day. 

9 The technology already exists for powertrain and 

10 transmission improvements. An analysis from the Union 

11 of Concerned scientists show that we can, as was 

12 earlier testified, with just a few percentage points do 

13 40 percent by 2025, and I urge you to strengthen these 

14 proposed regulations. 

15 Thank you again for the opportunity to speak to 

16 you. 

17 MR. TAMM: Okay. Thank you for your testimony. 

18 Could I have you introduce yourself? I wasn't sure of 

19 the right pronunciation, and it might be a lot simpler 

20 this way. Thank you. 

21 MR. FUGUITT: Yeah, that's a fair call. My name 

22 is Gus Fuguitt. I am a resident of Chicago, and I'm 
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1 here representing the Sierra Club. And I'm here today 

2 because I'm a young person who cares about the quality 

3 of the air and protecting the climate. When I first 

4 moved to Chicago, I lived in the back of the Yards 

5 neighborhood near the old stockyards. And when I came 

6 home from work, I would get off at the 47th Street red 

7 line train station, and I would walk down 47th Street 

8 to my apartment. And the 47th Street stop is right on 

9 the Dan Ryan Expressway, and 47th Street over there is 

10 a pretty heavy transportation corridor. 

11 And every day when I walked home, I noticed how 

12 the trucks that would affect my breathing and my head, 

13 because I suffer from my mild asthma. And walking down 

14 that street every day, I would just kind of pause to 

15 think how lucky I was that I had access to an inhaler 

16 and other medical services, and thought about how much 

17 worse other people in Chicago would have it. Earlier 

18 today I found out Chicago's air quality received an "F" 

19 grade from the American Lung Association, which is 

20 pretty terrifying to think about. 

21 But I'm primarily involved in the Sierra Club 

22 because of my fear and concern about climate change. 
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1 And I think that these rules would be a great step in 

2 the right direction to curbing the effects of global 

3 warming right now. People have said today that 

4 standards would cut oil use by over a million barrels 

5 every two days under these proposed rules. And over 

6 the lifetime of trucks sold under the proposed 

7 standards, the U.S. would avoid one billion metric tons 

8 of carbon pollution, which is pretty incredible to 

9 think about. 

10 And when you consider the current average mile per 

11 gallon standard of trucks haven't changed in decades, 

12 and that their greenhouse gas emissions are 

13 disproportionate to their presence on the road relative 

14 to all their vehicles, it just makes the urgency to

15 tackle this problem in this area even more apparent. 

16 So when I hear about people on this panel discussing 

17 how the technology already exists to meet these 

18 standards, and new standards would help save trucking 

19 companies money through efficiency and consumers 

20 through lower costs, not to mention the huge savings to 

21 our public health through lower emissions, it's just so 

22 clear to me that we need to take action on this issue. 
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1 A lot of people have been talking about the pretty 

2 historic announcement President Obama made on Monday 

3 about the Clean Power Plan, and he quoted a U.S. 

4 governor talking about, "We are the first generation to 

5 feel the impact of climate change, and the last to be 

6 able to do something about it." So ultimately I think 

7 we can't afford not to enact a common sense initiative 

8 like this in making our trucks more efficient. And I 

9 urge the EPA to finalize stronger standards that would 

10 reduce trucks' fuel use by 40 percent by 2025. 

11 Thanks again for the opportunity to speak today. 

12 MR. TAMM: Okay. Thank you very much, and thanks 

13 to this panel for your testimony. Are there any 

14 questions? 

15 (No response.) 

16 MR. TAMM: Okay. So thank you very much. If we 

17 could ask the panel that's in the staging area to come 

18 forward. Please do. And we'll announce the next 

19 panel. Actually once this next panel concludes their 

20 comments, then we'll break for lunch. 

21 MR. GRUNDLER: Mr. Zurakov, when you're ready,

22 please proceed. 
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1 MR. ZURAKOV: Thank you. I'm Michael Zurakov from 

2 Skokie, Illinois. I'm here as a private citizen, and I 

3 want to acknowledge the support and assistance of both 

4 the Sierra Club and the Union of Concerned Scientists. 

5 Without their support and encouragement, I probably 

6 would not be participating. 

7 I'm here today because of my longstanding 

8 engagement with the growing global crisis that is human 

9 caused climate change. As President Obama and so many 

10 others have stated, it's the most crucial issue of our 

11 generation. The impacts of climate change in the 

12 coming decades will probably constitute the greatest 

13 threat our civilization has ever faced. Even more 

14 important, the science and the mathematics tell us very 

15 clearly that the time is short. We must act quickly, 

16 decisively, and globally if we are going to avert the 

17 most catastrophic effects. To that end, we must 

18 dramatically reduce greenhouse gas emissions from all 

19 sources, including the transportation sector. 

20 My personal commitment to this has taken our 

21 household through several changes. In 2005, we changed 

22 to a gas/electric hybrid car for everyday use. In 
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1 2008, we modified it to plug in; that is, to use some 

2 grid electric power. In 2013, we acquired a pure 

3 electric car for local travel. So over a 10-year 

4 period, these steps saved about 2,800 gallons of 

5 gasoline and several tons of tailpipe emissions. 

6 In that respect, I have taken action as a private 

7 citizen to reduce oil consumption, but I know that much 

8 is needed. As some have put it recently, carbon 

9 consumerism cannot save the planet. I saw the other 

10 day and couldn't resist it. Only far-reaching actions 

11 by policymakers can achieve the serious cuts that are 

12 needed, and, of course, that's where you come in. 

13 Having addressed fuel efficiency standards for

14 passenger vehicles, the obvious step now is to address 

15 the fuel efficiency for all classes of trucks. So I 

16 applaud the Administration for proposing standards that 

17 will make our trucks more efficient in years to come. 

18 In addition to the greenhouse gas reductions, these

19 standards will drive innovation, will create jobs, and 

20 save the trucking industry billions of dollars in fuel 

21 costs, which then spreads through the economy. 

22 As I understand them, the proposed standards will 
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1 reduce fuel consumption some 36 percent by 2027, 

2 resulting in a 2035 savings of 550,000 barrels of oil 

3 per day. However, a recent UCS analysis finds that

4 reducing new truck fuel consumption 40 percent by 2025 

5 is both cost-effective and technically feasible. 

6 Therefore, the current proposal should be strengthened 

7 to save an additional 200,000 barrels of oil per day in 

8 2035. The urgency that is the rapidly closing window 

9 of opportunity for climate action makes it imperative 

10 that we reduce emissions as fast and as quickly as 

11 possible. 

12 Again, I applaud the Administration for proposing 

13 standards to make our trucks more efficient, and I urge 

14 you to finalize even stronger standards to the greatest 

15 extent feasible. I just hope it's not too late. Thank 

16 you for the opportunity to speak today. 

17 MR. GRUNDLER: Thank you so much for your 

18 comments. Ms. Perry, welcome. 

19 MS. PERRY: Hi. Welcome. Thank you for letting 

20 me have this opportunity to testify. I am a resident 

21 of Wilmette and representing Sierra Club. 

22 So I wanted to tell you what happened 10 years ago 
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1 when my son was in grammar school. I had read a small 

2 study about riding school buses is linked with 

3 increased incidence of asthma attacks and lung cancer. 

4 So after reading that, I decided promptly I'm going to 

5 drive him to school. So then recently I went to a Glen 

6 View environmental town hall to see has anything been 

7 done about this issue, about diesel exhaust emissions. 

8 And I talked to legislators and environmental experts, 

9 and they weren't sure. They didn't think anything was 

10 going on. 

11 So I dug more deeply, and I found out that if you 

12 have a new bus, considered model 2007 or later, then 

13 that is required to have pollution controls. But for 

14 anything 2006 and earlier, which I don't consider that 

15 old, but they're considered old buses, 2006 and 

16 earlier, these buses have no regulations for diesel

17 exhaust emissions. 

18 And I just want to tell you since I read that 

19 little small study, there's been a growing number of 

20 studies about the harmfulness of diesel and exhaust

21 exposure linked to heart disease, lung cancer, cancer, 

22 strokes, and other premature death. In fact, the World 
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1 Health Organization in 2012 confirmed this. 

2 So what I'm asking -- you know, and I also want to 

3 say not only is diesel bad for all of us, but kids 

4 riding these schools because they're young, their lungs 

5 are immature, and they breathe at a quicker rate, so 

6 they are inhaling more pollution. 

7 So I would like to see -- oh, before I go to my 

8 conclusion, I would like to -- I did a small little

9 sampling. I decided to call North Shore Transit 

10 Service, which operates 2,200 buses in my area, so it's 

11 Winnetka and North Shore suburbs. And I asked them, I 

12 said, so how many of your buses were made before the 

13 model year 2007, and they said half the fleet of 2,200. 

14 So, again, I was shocked that this has not been 

15 resolved, and I would like any school bus model 2006 

16 and earlier to have the same requirements and pollution 

17 controls as the 2007s and above. So millions of 

18 children are riding these old school buses inhaling

19 fumes that are lodged in their lungs and going into

20 their bloodstreams, and nothing is being done about it. 

21 They're just waiting for these school buses to expire, 

22 you know. 
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1 So thank you. I thank you for your time. I thank 

2 you for listening. And I hope there will be new 

3 regulations in the future. 

4 MR. GRUNDLER: Thank you for your testimony. 

5 Under the law that we administer, we're only allowed to 

6 regulate new vehicles. But every new vehicle on 

7 highway since 2007 is equipped with a filter. For what 

8 we call the legacy fleet, we do have a program to 

9 provide grants to school districts and others to 

10 retrofit or replace older diesel vehicles, but, of 

11 course, the need far, far outstrips the resources 

12 available. 

13 MS. PERRY: But there's no requirement -- 

14 MR. GRUNDLER: Correct. 

15 MS. PERRY: -- so these companies aren't picking up 

16 on it -- 

17 MR. GRUNDLER: That's right. 

18 MS. PERRY: -- because I read the letters. The 

19 EPA was terrific. You know, they're saying we have a 

20 grant to retrofit your bus, you know. But, no, they're 

21 not responding because there are no regulations. 

22 They're not required to do so. 
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1 MR. GRUNDLER: That is true. 

2 MS. PERRY: Thank you very much. 

3 MR. SILVERMAN: I would add the proposal on glider 

4 kits is to deal at least with rebuilt older vehicles 

5 where essentially new engines is put onto an old 

6 chassis and a claim made that it's an older vehicle. 

7 We're addressing that in this proposal as well. 

8 MS. PERRY: Well, that would be great because I 

9 heard there's leakage in the engine and in the 

10 tailpipe, and these kids are breathing it every day. 

11 Thank you so much. 

12 MR. GRUNDLER: Mr. Fuller, welcome. 

13 MR. FULLER: Thank you. My name is Tony Fuller. 

14 I'm a volunteer with the Sierra Club here in Chicago, 

15 and have been concerned about the threat posed by 

16 carbon pollution and the resulting climate disruption. 

17 I would like to thank the U.S. EPA and DOT for these 

18 second phase standards to reduce carbon pollution and 

19 oil use from heavy duty freight vehicles and trucks. 

20 However, these standards need to be strengthened 

21 to achieve at least a 40 percent reduction by 2025. 

22 The science shows that the technology exists to do 
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1 this. Strong 40 percent reduction standards are what I 

2 call really a no-brainer decision. Increased standards 

3 would yield additional health, economic, and 

4 environmental benefits with minimal costs, especially 

5 when you factor in the long-term threats posed by 

6 climate change and the health and economic benefits. 

7 Also I was thinking given the larger role the Federal 

8 government has been taking in healthcare and the costs 

9 associated with it, the monetary savings for the 

10 government alone should be a factor that should be 

11 considered. 

12 The U.S. EPA and the DOT also have a moral 

13 obligation to future generations to adopt strong 

14 standards. We are in a race to prevent a global 

15 temperature rise of two degrees above pre-industrial 

16 times, to limit the impacts that climate change would 

17 have on this planet. Unfortunately, current plans 

18 don't go far enough. According to Climate Action 

19 Tracker, a group of research organizations dedicated to 

20 analyzing the world's progress, U.S. action plans are 

21 short of what's needed. 

22 By increasing these second phase standards to a 40 
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1 percent reduction, we could take one step towards 

2 limiting the impacts of climate change. Anything else 

3 endangers not only our own health and economic well4 being, but the future for our families and the planet. 

5 Thank you. 

6 MR. GRUNDLER: Thank you for your comments. Ms. 

7 Fort, you're up. 

8 MS. FORT: Thank you to each of you for your 

9 public service, and I appreciate your hard work. As a 

10 director who sat through hours of auditions, I 

11 appreciate the quality of your listening. 

12 (Laughter.) 

13 MS. FORT: It's very hard work. And I appreciate 

14 the opportunity to testify. 

15 I'm Karen Fort, and I belong to actually five or 

16 six environmental organizations. It was the Union of 

17 Concerned Scientists that brought me here, but I'm most 

18 active with Citizens Climate Lobby. We consider 

19 ourselves your ally because you've got to choose either 

20 regulations or carbon tax, or cap and trade, or all of 

21 them. Let's do all of them. 

22 So I read these standards, and I think, yes, they 
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1 are an important step in the right direction. For 45 

2 years we have had absolute stagnation in the 

3 innovation, so we have lots of technologies. They've 

4 gotten more efficient over the decades. We have better 

5 light bulbs and homes and appliances. But heavy duty 

6 truck fuel economy has barely changed since the 1970s, 

7 okay? I'm 63. I was 18. That's just really stupid. 

8 That's a failure of the free market there. 

9 The proposed heavy duty truck fuel efficiency 

10 standards win three ways. They reduce oil consumption. 

11 They reduce global warming emissions. They reduce

12 consumers' expenses. So commercial trucks can save -- 

13 can save fuel, use less, save billions of dollars. And 

14 these regulations will create tens of thousands of 

15 jobs. 

16 You are stuck between the laws of physics which 

17 never compromise with anybody, and the laws of 

18 politics, which is the art of the possible. You are 

19 called the "Environmental Protection Agency." The 

20 spirit of that mission is larger than this hearing, and 

21 you are my heroes. The day-to-day listening to the

22 petty details as we grind forward step by step is part 
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1 of a much larger truly noble ethical enterprise, and it 

2 requires us to be statesmen rather than politicians. 

3 So I want to thank you again. 

4 Let's see. The need for emergency climate action 

5 really makes it critical. Frankly I'm scared. There 

6 are unknown tipping points. We are not just talking 

7 about heat stroke or asthma. We are talking about 

8 potentially the death of an ecosystem which supports 

9 all life on our planet. We just don't know how to 

10 really say that very often because it's so scary. And 

11 so, we don't. We say the "devastating effects of 

12 climate change," and we skip over 100 million starving 

13 refugees that when my grandchildren are my age they

14 will witness. It will dwarf World War II in its 

15 suffering if we do not act right now. 

16 So because it's an emergency, because a stitch in 

17 time saves nine, strengthen this standard to 40 percent 

18 by 2025, and if someone has a breakthrough in 

19 technology before 2030 -- 

20 Now, this law prevents any further changes until 

21 2030, but if there's a breakthrough, please, could we 

22 amend that? Could we please institute all the 
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1 technology we've got all the time as fast and as hard 

2 as we can, because really here this is a matter of life 

3 and death. The chips are down. We must push really 

4 hard. 

5 We need an insurance policy. We don't know enough 

6 to be complacent, to have good business alternatives 

7 that place no onerous expenses, blah, blah, blah. We 

8 can get this at least, even in the political realities, 

9 which these regulations will face, we can at least get 

10 to 40 percent. We know we have those technologies 

11 ready to go. They are ready to be deployed right now. 

12 And we can argue against, say, the Supreme Court's 

13 objecting that this might place an onerous burden on 

14 our economy by saying, yeah. Just bring it from 6.3 

15 miles a gallon, or if it's full four, up to 10.7 miles 

16 a gallon. And if you can make your tractor trailer

17 more efficient, you save $30,000 in fuel costs for each 

18 trucks, each year, enabling people to recoup their 

19 investment in just a little bit more than a year. 

20 The rule runs until 2029 and prevents 

21 improvements. Please change that. We have this 

22 opportunity right now. The window is closing, but it's 
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1 not too late. There is even economic opportunity for 

2 profit in the transition from strategic to sustainable 

3 jobs. Thank you. 

4 MR. GRUNDLER: Thank you. Thank you, Ms. Fort. 

5 Mr. Natkin? 

6 MR. NATKIN: Good afternoon. I'm Bob Natkin. I'm 

7 from American Power Group. American Power Group makes 

8 what EPA would call mixed fuel systems. We have the 

9 greatest amount of outside useful life and inside 

10 useful life approvals from the EPA and just started

11 getting our ARBEO certifications for this system. And 

12 I'm going to be a lot more detailed because I am an

13 engineer. 

14 I'm in my 40th year in the automotive industry. I 

15 spent 32 years at Ford working on spark ignition 

16 engines, designing, developing, enhancing after 

17 treatment systems also. And as one who's traveled to 

18 China and to Europe throughout my career, I can tell 

19 you that I personally appreciate the need for air 

20 quality regulation. I truly do, especially after my 

21 last trip to China. 

22 Okay. So the mixed fuel system that I'm speaking 
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1 about is able to reduce diesel fuel consumption on the 

2 order of 50 percent. It's a mixed fuel, which means it 

3 simultaneously operates with diesel and natural gas at 

4 the same time. Now, in doing that we get on the order 

5 of 10 percent CO2 reduction, and on the order of 25

6 percent or greater NOx reduction. This is all 

7 reflected in the data that is in our approvals, so EPA 

8 and ARB have all this information. I'm not telling you 

9 anything new here. 

10 But we do have some questions, and I have a list 

11 of six that I've submitted to you, and I'll go through 

12 them very quickly. 

13 We would like to -- as a small volume 

14 manufacturer, we'd like to better understand how these 

15 Phase 2 proposed greenhouse gas rules will be affecting 

16 the OUL and the IUL approval criteria. Question two. 

17 As a small volume manufacturer for clean alt fuels, can 

18 we accumulate some sort of emission credits for the

19 emissions that we do reduce? 

20 Question three, and, of course, I don't expect

21 answers here. I expect your technology -- your 

22 technology engineers to come back to us with this. As 
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1 you go from 2017 to 2027, there's reduction in CO2, of 

2 course, that's directly related to fuel economy 

3 improvements. But the CO2 measurement is based on a 

4 dynamometer -- an engine dynamometer test, either the 

5 RMC-13 or the heavy duty transient. I'm very familiar 

6 with these tests because I run them all the time. 

7 That is an engine test, so some of these fuel 

8 economy improvements are reflected in vehicle 

9 improvements. We've already heard people talking about 

10 aero for trailers, aero for cabs, tire technology, 

11 transmission technology. So my question back to you 

12 is, how will those vehicle fuel economy improvements be 

13 reflected or in the engine -- the engine dyno test. 

14 Are you going to modify, put a correction factor on the 

15 results, or are you going to modify the test? Okay. 

16 Question four. With respect to greenhouse gas

17 emissions standards for small-volume manufacturers in 

18 Part 86.19-14, you're allowing for heavy duty 

19 manufacturers to be exempt from the greenhouse gas 

20 standards before January 2019. And then if it's not a 

21 standard type fuel, that extends to 2020, January 1st. 

22 With respect to Subpart 1036.150, the interim 
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1 provision -- this is for gasoline engine manufacturers 

2 -- you're taking the small-volume manufacturer 

3 exemption to January 2022, and if it's -- you're not 

4 putting gasoline 85 or diesel fuel, that extends to

5 2023. 

6 So what that is saying is there's a discrepancy 

7 between the exemption allowed for the heavy duty engine 

8 small-volume manufacturer and the spark ignition engine 

9 small-volume manufacturer. And are we reading this

10 correctly, or if we're not correct, why is there a 

11 discrepancy between those two? 

12 The commentary is number five, and this gets 

13 fairly technical, but I can tell you that -- I'm not 

14 going to read through the whole thing. But as you 

15 convert an engine from spark -- either from spark 

16 ignition or more so from compression ignition, to 

17 either dedicated natural gas or dual fuel, as we call 

18 it, mixed fuel as you call it, there are things that 

19 occur, and it's laid out in the information that I've 

20 given you, that will result increased emissions of 

21 methane. You're not going get around it unless you go 

22 in and redesign the engine. I know how to do it. I 
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1 used to do it at Ford. 

2 But the small-volume manufacturer converters for 

3 natural gas are not privy to making these significant 

4 engine changes, so they're going to suffer. Right now 

5 if you look at the large manufacturer emission data

6 that's available in the EPA database, you're going to 

7 find that converted engines are running between one and 

8 two grams per brake horse power hour. Your regulation 

9 for methane is proposed 0.1. That's a 90 percent 

10 reduction to 95 percent reduction over what they 

11 already have. 

12 Now, in after treatment -- 

13 MR. GRUNDLER: Mr. Natkin, I'm going to have to 

14 ask you to wrap it up. 

15 MR. NATKIN: Yeah, okay. There's issues in after 

16 treatment that they're not being addressed, and they 

17 are listed in here. 

18 My last question which I will ask you to consider 

19 is my company is currently dealing with capturing, 

20 filtering, and using flare gas that you're finding -- 

21 we're finding in the Bakken. And we want to know if 

22 there's any consideration for a company that's taking 
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1 gas that would normally be flared to being used for

2 useful work. 

3 So that concludes my request. 

4 MR. GRUNDLER: Thank you very much, and with 

5 respect to your questions, if you stop and speak to one 

6 of our team outside, we can get you a contact for 

7 someone who can explain what we've done, and hopefully 

8 answer some of your questions, if not all of them. 

9 MR. NATKIN: Thank you. 

10 MR. GRUNDLER: Dr. Kissane, welcome. 

11 MS. KISSANE: Hello. Thank you. I'm glad to be 

12 here. I'm going to down the Kennedy Expressway when 

13 the fumes from a rolling carbon dioxide factory are

14 enveloping my car. The semi gains on me as I break the 

15 speed limit trying to get over to the next lane. Go 

16 back to normal breathing, but not for long as my nose 

17 picks up acrid fumes from an oncoming truck. 

18 Well, what could be done about this problem? Last 

19 week I visited a car dealership, and I was impressed at 

20 the increased MPG the new 2015s were capable of. Then 

21 the thought struck me: why not make truck 

22 manufacturers increase the MPGs on their vehicles? Not 
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1 only would this lower the total amount of carbon 

2 dioxide in the air, but would save truck companies gas 

3 dollars, savings of which they might pass along to the 

4 consumers of the goods they transport. 

5 I wish to thank the EPA for its recent progress 

6 towards reducing pollution, and heartily encourage you 

7 to continue down the path of a more livable environment 

8 for all. Thank you. 

9 MR. GRUNDLER: Thank you very much. Any questions 

10 for this panel? 

11 (No response.) 

12 MR. GRUNDLER: Thank you again for your time, and 

13 for your comments, and for your passion for this 

14 democratic process. 

15 We will now break for lunch. It's 12:30. We are 

16 exactly on schedule. We will reconvene in one hour. 

17 (Lunch recess.) 

18 MR. GRUNDLER: Okay. We're ready to begin. I’d 

19 like to ask panel number seven to make their way over 

20 to the staging area. Mr. Kunkel, Mr. Gilroy, Ms. 

21 Richardson, Mr. Cohn, Mr. Grenerth, Mr. Brubaker, and 

22 Ms. Delaney will be our next panel. And up now is 
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1 panel six. Welcome to our hearing. Ms. Gordon, 

2 whenever you're ready. Good to see you again. 

3 MS. GORDON: Good afternoon. I'm Debbie Gordon, 

4 executive director of regulatory issues and hybrid 

5 programs for Allison Transmission. Allison 

6 Transmission is the world's largest manufacturer of

7 fully automatic transmissions for medium and heavy duty 

8 commercial vehicles, and is a leader in hybrid 

9 propulsion systems for city buses. 

10 Allison transmissions are used in a variety of

11 applications, including refuse, construction, buyer, 

12 pickup and delivery, distribution, bus, motor homes, 

13 defense, and energy. Our global headquarters are in 

14 Indianapolis, Indiana, and I'm proud to say we're 

15 celebrating our centennial year. 

16 Over the last six years, Allison has engaged with 

17 EPA and NHTSA regarding the two Agencies' efforts to 

18 address the greenhouse gas emissions and fuel 

19 efficiency of medium and heavy duty vehicles. During 

20 this time, we've always been afforded the opportunity 

21 to directly engage with EPA and NHTSA technical staff 

22 and management. In addition, Allison has supported
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1 efforts by EPA and NHTSA to test transmissions and 

2 increase the base knowledge that both Agencies have

3 with regard to the effect of transmission systems on 

4 greenhouse gas emissions and fuel efficiency. 

5 Our overriding concern has been that any 

6 regulations that affect transmissions and our customers 

7 accurately reflect the capabilities of fully automatic 

8 transmission systems and hybrid systems. We've also 

9 emphasized the importance of assessing the relative

10 performance of vehicles and transmission systems with 

11 respect to the real world operating conditions of 

12 commercial vehicles. 

13 It's a considerable understatement to note that 

14 the Phase 2 rule is a complicated rulemaking. We're 

15 still in the process of reviewing the rule and its 

16 supporting technical analysis. But one thing is 

17 abundantly clear: the greenhouse gas emission model, 

18 or GEM, plays a crucial role in Phase 2 regulations. 

19 GEM literally determines how you comply. 

20 Allison fully supports EPA's ongoing efforts to 

21 make GEM more accurate and more representative of real 

22 world vehicles. We also recognize the use of GEM as a 
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1 primary certification methodology, but we have some

2 significant concerns with the quality of GEM's software 

3 and EPA technical and policy choices regarding GEM.

4 First, GEM does not run well. When GEM was 

5 delivered, there were missing files, and then we got it 

6 to run, there were a number of coding errors 

7 identified. Secondly, the model produces unrealistic 

8 operation of the duty cycles. The lockup shift 

9 strategy and the neutral loading and automatic neutral 

10 functionality are inappropriate. And finally, there 

11 are major deficiencies in the base control algorithms. 

12 Some production vehicle configurations would not shift 

13 out of first range. Others do not downshift to highway 

14 speeds when the load is encountered. We've also seen 

15 the GEM controller release lockup at highway speeds

16 which would never happen. 

17 These examples do not reflect how fully automatic 

18 transmissions operate, and flaws in GEM will directly 

19 translate into flaws in the final rule. In short, GEM 

20 is not ready for prime time as a certification tool. 

21 Given this situation, we believe that EPA and NHTSA

22 must be mindful of the procedural requirements of the 
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1 Clean Air Act and the Administrative Procedure Act. 

2 Adequate opportunity for comment must be provided, 

3 especially with regard to a central element of the 

4 rulemaking such as GEM. 

5 With regard to GEM, the devil really is in the

6 details. It's impossible to understand and reasonably 

7 project the effect of any final rule without 

8 understanding precisely how GEM will operate, what it 

9 will measure, and how it will assess different systems. 

10 This is especially true in the vocational vehicle 

11 market where there are hundreds of different vehicle 

12 types, and is amplified where, as here, EPA and NHTSA 

13 intend to decrease greenhouse gases and improve fuel 

14 efficiency through the deployment of new technology. 

15 When GEM executable files will not run, when other 

16 errors are found in GEM, when delays occur in making 

17 changes to the model, the very process of public 

18 comment period is called into question. Without 

19 refinement, GEM results could be considered arbitrary. 

20 To be clear, we intend our comments not as the

21 reflection of the hard work of EPA and NHTSA or their 

22 staff. Instead, our criticism is a reflection of the 
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1 extremely complicated nature of the proposed rule and 

2 its heavy reliance on computer modeling. 

3 We believe that there are several ways EPA can

4 address this situation. One avenue would be to extend 

5 the comment period to allow sufficient time to resolve 

6 GEM bugs and to allow the public sufficient time to run 

7 the model and fully understand its implications. In 

8 our view, there is no downside to this option since

9 there is no legal deadline for a final rule. Another 

10 possible avenue would be to reopen the public comment 

11 period when GEM is further developed. Other 

12 administrative avenues are potentially available, 

13 including issuing a notice of data availability with an 

14 opportunity to comment. 

15 Allison Transmission is looking forward to 

16 continuing to work with EPA and NHTSA, but we ask now 

17 at this stage that the agencies recognize GEM needs

18 further refinement to allow for public comment, and

19 that overall the operation of the model must be 

20 improved. We urge EPA and NHTSA to seriously consider 

21 this matter before the announced deadline for the 

22 submission of comments. Thank you. 
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1 MR. GRUNDLER: Thank you. Mr. Lackore. 

2 MR. LACKORE: Good afternoon. My name is Roger 

3 Lackore. I'm employed Oshkosh Corporation, and I've 

4 worked in heavy truck design for 30 years. Oshkosh

5 Corporation supports the intent of this proposed rule 

6 and its endeavor to serve the interests of the 

7 environment and energy conservation. We do, however, 

8 wish to point out certain areas where we believe the 

9 rule as proposed will be counterproductive as it 

10 relates to vocational vehicles. 

11 Heavy vocational trucks are characterized by niche 

12 applications, low volumes, and special purpose designs. 

13 Example segments include dump, plows, utility, refuse, 

14 fire, and concrete delivery. Within each segment, 

15 there are often widely varying vehicle types. There 

16 are, for instance, seven unique types of refuse 

17 collection vehicles as one example. This extreme 

18 variability and complexity renders a design 

19 prescriptive regulation untenable. 

20 The Phase 2 plan mandates a 16 percent improvement 

21 for heavy vocational trucks, four percent of this 

22 coming from the engine. The remaining 12 percent is 
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1 expected to come from applying seven technologies. Of 

2 these seven check the box technologies, none of them 

3 can be practically applied to most vocational 

4 applications. 

5 The first and most optimistic technology is 

6 advanced transmission and engine integration. This

7 approach matches the transmission control algorithms to 

8 the engine performance tailored to a specific duty 

9 cycle. While this may be practical for high volume

10 line haul applications, we believe it is unlikely to 

11 succeed in the low volume vocational world. The myriad 

12 range of vocations lead to a corresponding myriad of 

13 duty cycles, engine and transmission makes, models, and 

14 power ratings. Creating specialized engine and 

15 transmission integration algorithms takes time, money, 

16 testing effort, and a market driver. Engine and 

17 transmission suppliers will have little interest in

18 creating the literally hundreds of optimizations needed 

19 to cover the low volumes that each combination will

20 represent. 

21 The second checkbox involves switching from 

22 traction capable six by four drive tandems to a six by 
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1 two on road tandem. This checkbox will not work for 

2 most vocational trucks that spend part of their life in 

3 off road environments, such as job sites, landfills, 

4 power line paths, et cetera. 

5 Checkbox three is smart stop technology. Shutting 

6 off the engine at every stop will not be practical for 

7 fire apparatus where every second counts on the way to 

8 the emergency. Shutting off a mixer engine will stop 

9 the drum from rotating and risk the concrete setting up 

10 in the drum. Refuse trucks need engine running when 

11 they stop to operate collection and packing equipment. 

12 Checkbox four, neutral idle technology. This 

13 approach shifts the transmission to neutral whenever 

14 the engine is at idle. Certain vocational trucks spend 

15 a lot of time at idle, but the transmission is already 

16 in neutral, and the engine power is performing work at 

17 that time. 

18 Checkboxes five and six involve further 

19 improvements to tire rolling resistance. Phase 1 is 

20 already mandating improvements, and we believe that by 

21 2017, further rolling resistance improvements will not 

22 be possible without degrading the traction capabilities 
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1 that most vocational trucks require. Even if rolling 

2 resistance could be reduced without sacrificing 

3 traction, the proposal correctly points out that the 

4 tire manufacturers have little incentive to put 

5 research into those tire sizes appropriate, only for 

6 low volume vocational applications. 

7 The seventh and last checkbox involves weight 

8 reduction. For applications like concrete or refuse, 

9 less weight is already a huge market driver. The plan 

10 suggests a switch to aluminum rims as a most likely

11 possibility, but front discharge concrete mixers and 

12 fire apparatus already use 100 percent aluminum rims. 

13 Another suggestion involves redesigning structural 

14 components using higher strength steel, but the 

15 inherent thinner material are more rapidly degraded by 

16 corrosion and exacerbate a major problem in the 

17 trucking industry already caused by the increased use 

18 of liquid de-icing agents. 

19 The Phase 2 proposal requires that vocational 

20 vehicle manufacturers check these boxes on the seven 

21 technologies in order to show compliance. As we can 

22 see, these boxes either can't be checked, or if they 
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1 are checked, doing so will not result in actual real 

2 world improvements. Besides being ineffectual, the

3 checkbox approach creates an unfair hardship for those 

4 manufacturers whose only products are vocational in

5 nature. Large truck manufacturers have the option to 

6 offset noncompliant vocational trucks with credits from 

7 line haul products. This is not possible if you only 

8 produce vocational products. 

9 This dilemma deals a double whammy to business, 

10 vocational only manufacturers will be out of the 

11 business and new entrepreneurial ventures will be 

12 blocked. We propose the following solution. We 

13 suggest that the U.S. Congress and the EPA acknowledge 

14 the fact that the laws of physics simply do not allow 

15 heavy vocational work trucks the same potential for CO2 

16 and fuel economy improvements as is possible for the 

17 higher speed line haul application. Slower speeds, low 

18 volumes, off road operation, complex duty cycles, lack 

19 of engine and transmission supplier market drivers, and 

20 the nature of the work being performed all work against 

21 the vocational product. 

22 The Phase 2 regulations should, therefore, 
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1 continue the current Phase 1 tire regulations as is and 

2 limit further mandates to whatever can be gleaned from 

3 the engine improvements alone. Thank you. 

4 MR. GRUNDLER: Thank you very much. Mr. Quealy, 

5 welcome. 

6 MR. QUEALY: Hello, and good afternoon. My name 

7 is Kevin Quealy, and thank you again for the 

8 opportunity to testify today. As a student of the 

9 University Illinois enrolled in the Department of 

10 Natural Resources and Environmental Science, I am 

11 testifying today on behalf of the Sierra Club and 

12 representing my hometown of Lansing, Illinois. And I'm 

13 here today to urge the EPA and Department of Treasury 

14 to consider stronger and more aggressive efficiency

15 standards regarding medium and heavy duty freight 

16 trucks. 

17 I would like to begin my testimony today with a 

18 short personal story. I lived the first 10 years of my 

19 life in a small home in Lansing located on Interstate 

20 294, and I remember clearly on summer days like today 

21 going out to play with my friends in the neighborhood, 

22 and clearly seeing a visible cloud of exhaust hovering 
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1 over the expressway, and sometimes even creeping as far 

2 as my own backyard. 

3 Now, the seemingly endless sign of trucks filled 

4 the expressway as the strong stench of burning fuel

5 invaded the neighborhood. And looking back at my own 

6 childhood, I've come to realize that children and 

7 future generations should not have to tolerate the same 

8 disruptive and potentially even hazardous circumstances 

9 and conditions that I went through when I was younger. 

10 Luckily, I do not have any asthmatic conditions, but 

11 as you can hear from the people who were testifying

12 earlier, it is a very common problem, especially in the 

13 Chicagoland area. 

14 The current proposed standards are absolutely a 

15 step in the right direction to mitigate the damage not 

16 only to public health, but also to the atmosphere. I 

17 do appreciate the efforts put forth by the Agency to 

18 support a cleaner planet with more resource conscious 

19 decisions. However, I do believe that significant 

20 progress will not be made in a timely manner if the EPA 

21 does not implement a full-fledged attack on carbon 

22 pollution released by the truck fleets that fill our 
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1 Nation's roadways. 

2 The technology to further improve freight truck 

3 efficiency is feasible and tangible, ranging from 

4 improved aerodynamics on trailers to electric 

5 drivetrains powering the vehicle. These 

6 implementations are only two of the many examples that 

7 manufacturers connect in conjunction with the EPA in 

8 order to reduce total oil consumption. 

9 Now, according to the Union of Concerned 

10 Scientists, strengthening the current proposed 

11 standards would save an additional 200,000 barrels of 

12 oil per day by the year 2035, and would also avoid 40 

13 million metric tons of greenhouse gas emissions 

14 annually, which is the equivalent of shutting down 12 

15 entirely coal-fired power plants. 

16 Now, interstate freight transport is definitely an 

17 integral facet of our Nation's transportation sector 

18 and a critical part of the United States economy. And 

19 this is something that even the most staunch 

20 environmentalist could not deny. But the success of 

21 the industry is absolutely heavily beneficial to our 

22 Nation, but when additional advancements are within the 
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1 realm of possibility, any action to reduce carbon 

2 emissions are highly encouraged by not only myself, but 

3 also the University of Illinois and the Sierra Club. 

4 Strong standards to reduce trucks' fuel use by 40 

5 percent by the year 2025 should be a top priority of 

6 the Agency. Thank you again for your time and allowing 

7 me to testify today. 

8 MR. GRUNDLER: Thank you. Thank you for making 

9 the trip up to Chicago. Mr. Freiler, welcome. 

10 MR. FREILER: Thank you. Good afternoon. My name 

11 is John Freiler, and I'm here representing the Truck 

12 Trailer Manufacturers Association, or TTMA. I'll be 

13 addressing only the trailer specific portions of this 

14 proposed rule. 

15 TTMA is an international trade association of 

16 heavy duty trailer builders with members across North 

17 America. Approximately 90 percent of all trailers 

18 operating in the United States were built by TTMA 

19 members. We at TTMA want to express our appreciation 

20 at the outreach the government regulatory agencies have 

21 made to us and our members in the past 17 months. 

22 We've been working to convey the peculiar nature 
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1 of the trailer world. It's not one where millions of 

2 vehicles are made and then sold at your local 

3 dealership. That's automobiles. And it would take 65 

4 years of trailer production to equal what the 

5 automobile world puts out in one year. 

6 This is an industry that builds trailers almost 

7 exclusively for particular customer orders and to those 

8 customers' particular needs. The trailers can be quite 

9 specialized to meet those needs, so variation is the 

10 norm rather than the exception. 

11 The customers that the trailer industry serves are 

12 extremely cost conscious. The shipping business is

13 very competitive, and if there is a way that these 

14 shippers can shave a few percentage points off their 

15 costs, they will pursue that tenaciously. We see this 

16 is as our customers explore various technologies to

17 maximize fuel efficiency, and thereby reduce greenhouse 

18 gas emissions. That's one reason why the EPA SmartWay 

19 Program is so successful. It provides a way for 

20 trailer users to sort through the competing claims of 

21 device manufacturers. They get an unbiased source of 

22 information to judge how various technologies will work 
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1 in their fleets. 

2 We've also seen how such a good program could be 

3 spoiled when California made SmartWay compliance 

4 mandatory. Instead of actual fuel and greenhouse gas 

5 savings, you saw devices being fitted to check off a 

6 box. People who would see no gains from the technology 

7 would have to adopt it, or worse yet, freight would be 

8 diverted to exempt classes of trailers, such as 53-foot 

9 containers on the chassis, both of which actually serve 

10 to increase fuel consumption and greenhouse gas 

11 emissions. 

12 We have significant concerns about this proposal. 

13 Foremost is that this proposal could essentially 

14 become the California mistake writ large, that users 

15 would be required to fit devices to trailers or alter 

16 their basic trailer choices in a way that would not

17 only be costly and inefficient, but would ultimately 

18 serve to worsen the trucking industry's carbon 

19 footprint and safety record. 

20 We're concerned that this proposal doesn't seem to 

21 recognize that the trailers that would gain benefit

22 from application of SmartWay style technologies already 
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1 have done so. Also that the purported gains of the

2 rules seem to come exclusively from theoretical 

3 modeling rather than real world experience. 

4 If this rule is not to have unintended 

5 consequences, very careful thought will have to be 

6 applied to excluded classes of trailers. Further, some 

7 of our members are dubious of EPA's claims of authority 

8 to regulate our products at all. We also have issues 

9 with the widespread requirement of low rolling 

10 resistance tires and automatic tire inflation systems. 

11 We have issues with the warranties that the government 

12 is mandating, and industry disruptions from the 

13 averaging flexibilities. We also have ideas as to how 

14 the rule could be better crafted to accomplish its 

15 goals with the minimum of cost to the shippers, 

16 operators, and ultimately all consumers. 

17 We are not opposed to all regulations. TTMA has a 

18 long history of working closely with regulators to help 

19 craft sensible regulations that serve both the industry 

20 and the public. You can see this in the number of 

21 times information from TTMA is cited in various 

22 regulatory evaluations. But to accomplish this needs 
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1 time. As I said, the trailer industry is different. 

2 These are mostly small businesses often working in 

3 niche markets for a handful of customers. While the 

4 proposed regulation was crafted over the course of some 

5 16 months, our members have been given just a bit over 

6 60 days to respond. 

7 Just understanding what it means to have our 

8 products come under EPA rules is a daunting task that 

9 it is just one of the end written consequences of this 

10 proposal, in addition to the requirements in the 629 

11 pages of the printed document. We lack the dedicated 

12 engineering and legal man hours needed to properly 

13 respond to this rule in the allotted time. 

14 Therefore, I will end with this plea. We need

15 more time to respond to this proposal. We've submitted 

16 a petition to the docket to extend the comment period 

17 by at least 90 days, and 180 days would be preferable. 

18 It is still far less than the 500 days or so that the 

19 government spent writing it, and it could be of great 

20 help in actually achieving the agencies' goals of 

21 reducing fuel consumption and greenhouse gas emissions. 

22 Thank you for your time and this opportunity to 
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1 speak. I look forward to answering questions today, 

2 and will be available in the future if you should have 

3 any questions. 

4 MR. GRUNDLER: Thank you so much. Ms. White, 

5 you're up. 

6 MS. WHITE: Hi. I'm Catherine White. Two and a 

7 half years ago I thought I had the most important job 

8 in the world. I was a classroom teacher, and I was

9 proud of it. I made it a point to teach my kids that 

10 their job in life is to leave the world in better shape 

11 than when they arrived in it. 

12 Then during my last year of teaching I saw the

13 movie Gasland. It's about fracking. The movie didn't 

14 tell me anything that I didn't know. I read a lot 

15 about science. But sometimes art hits you in a way

16 that facts don't. I walked out of the movie terrified 

17 thinking, why am I wasting my time teaching kids who 

18 may not have water in 10 years? 

19 The next morning I called human resources about 

20 early retirement. Later that year, I realized that I 

21 didn't have to retire. I quit. I walked out of a 

22 well-paying job to make sure that my kids, our kids, 
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1 will have safe water. Safe water is not just a public 

2 health issue. It's a matter of global security. All 

3 over African countries are fighting over water. In the 

4 Middle East, people are fighting over the Tigris, 

5 Euphrates, and Jordan Rivers. Even within the United 

6 States, the southwest has agued that Great Lakes water 

7 is a national resource, not just water for the eight 

8 surrounding states. 

9 That brings me to the hearing today. I need your 

10 help to protect my kids. Our water supply is being

11 threatened by how we gain access to fuel, then again by 

12 the burning of those fuels. Drilling, fracking, leaks, 

13 explosions, disposal of waste, all pollute our water 

14 and cause global warming, which we know is a public

15 health and national security threat. Atmospheric 

16 carbon has grown in exact proportion to the amount of 

17 fossil fuels burned starting around 1850. 

18 We need to do everything in our power to cut oil 

19 use so that we protect the air and water for our kids. 

20 I'm happy that the Administration is proposing 

21 standards to make our trucks more efficient, but we can 

22 do better, and we must. Forty percent reduction by
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1 2025 is reasonable. The technology exists, it's 

2 affordable, and it's already being used in Europe. 

3 Their fuel efficiency is about twice ours. We can 

4 protect our truckers and our food costs by maximizing 

5 fuel efficiency which buffers against the unpredictable 

6 cost of fuel. 

7 Stronger efficiency standards will reduce 

8 healthcare costs, and since many oil refineries in 

9 places where trucks idle are in poor communities, 

10 raising these standards to 40 percent will have an 

11 especially strong impact on my kids, most of whom come 

12 from poor communities. 

13 I thank you for the opportunity to speak here, and 

14 I ask you once again help me protect our kids. Resist 

15 the pressure from the oil companies. Help us leave the 

16 world in better shape than we arrived in it. Thank

17 you. 

18 MR. GRUNDLER: Thank you so much for your 

19 comments. Ms. Frens, welcome. 

20 MS. FRENS: Thank you. I thank the panel and the 

21 other interested parties here for the opportunity to 

22 address you today. I worked for some 30 years in a
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1 major U.S. warehousing and transportation company 

2 primarily in the insurance company. I'm well aware of 

3 the efficiencies that producing most of our products in 

4 only a few places and using the trucking industry in 

5 order to distribute it promotes efficiencies and is a 

6 cost-saving measure. 

7 At the same time, I'm a resident of Elk Grove 

8 Village and a member of the Northwest Suburbs 

9 Organization for Action. You might think that out in 

10 the suburbs in the collar counties that we aren't as 

11 affected, but I would let you know that in the past few 

12 decades, both homes and businesses continue growing, 

13 and communities, such as Arlington Heights, Elgin, 

14 Mount Prospect, Wheeling, Palatine, Schaumburg, and

15 Barrington. 

16 There's growing congestion on our roads. Much of 

17 that growth is automobiles, but much of that growth is 

18 in trucking. As we speak, multiple-year construction 

19 on highways continues into the northwest suburbs. The 

20 Elgin O'Hare Expressway is vastly increasing the number 

21 of vehicles using the northwest/southeast corridor. 

22 Certainly there are a number of commuters who will be 
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1 using these new roads, but the volume of truck traffic 

2 is increasing significantly. 

3 Delivery of goods and transport of materials 

4 requires trucks, many trucks. New mega stores in the 

5 outer suburbs, increased terminals at O'Hare, delivery 

6 routes using perimeter routes around the mega cities, 

7 in addition to older routes into and out of Chicago, 

8 are increasing the trucking traffic throughout our 

9 communities exponentially. 

10 New road construction is doing much to reduce 

11 congestion in our suburbs. We're grateful for that. 

12 We anticipate the completion some time late 2016. 

13 Vehicles going to O'Hare will zoom by our communities 

14 with an occasional stop to refuel. Deliveries and 

15 trips to the farther suburbs will be much quicker. 

16 Deliveries will be so much more efficient. We 

17 anticipate what the completion of the projects will do 

18 for efficient transportation into and through our 

19 communities. 

20 But we also know what skies look like on humid, 

21 windless days. The smog that settles into our 

22 communities has grown in the 30 years I have lived in 
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1 Elk Grove with my family. We are fortunate to be 

2 healthy, but we are aware of classmates in grade 

3 school, older people in our church, and lines of people 

4 in the drugstore purchasing breathing devices and 

5 medications. 

6 Older schoolteachers tell us that the number of 

7 kids using inhalers has gone up significantly. I have 

8 an inhaler which I use on days when the atmosphere is 

9 polluted. This is too great a price to pay for quicker 

10 trips, quicker deliveries, less frustration in our 

11 transportation. We have concerns about the quality of 

12 our air as the number of trucks going through our 

13 communities increases. 

14 There is a solution. This solution is in front of 

15 us in the guidelines proposed by the Department of 

16 Treasury to reduce carbon pollution and oil use in 

17 freight trucks. We need to do this. Our corporations 

18 need to do this. Our children and children's children 

19 need us to do this. Our earth needs us to do this. 

20 Thank you. 

21 MR. GRUNDLER: Thank you very much, panel. I have 

22 a question for Mr. Lackore. Our proposal does have
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1 special provisions for emergency vehicles. It does

2 distinguish between line haul vehicles and vocational 

3 vehicles. Is it your testimony that these provisions 

4 don't go far enough in your opinion? 

5 MR. LACKORE: Well, not having gone through the 

6 whole 629 pages. I focused on the vocational section, 

7 which in my understanding, if you looked at it would be 

8 tables V17, 18, and 19 that point to the requirements 

9 that I talked to in my paper. So those are the ones 

10 that I understand vocational vehicles are going to be 

11 required to meet, and that was where I came from that. 

12 And then as far as emergency vehicles, my 

13 understanding from the proposal is that there's simply 

14 -- that the thought is to just delay implementation for 

15 emergency vehicles, but they would still be required to 

16 check the same boxes as in table V19 by 2027, just have 

17 more time to implement. And I would suggest that it 

18 isn't the time issue. It's really the physics that's 

19 the problem. 

20 MR. SILVERMAN: By the way, there is no 

21 requirement to use any particular technology to meet 

22 these standards. We are showing the way we derived
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1 them, but there is no design requirement. 

2 Manufacturers are free to choose any means within their 

3 desire, capability, et cetera, to achieve them. So

4 it's not exactly a check off the box. 

5 MR. LACKORE: Okay. I apologize if I 

6 misrepresented that. The issue is -- the inherent 

7 issue is that when you take a vocational vehicle, the 

8 biggest place that you can get savings from obviously 

9 is aerodynamics. None of our vehicles are aerodynamic. 

10 You look at a concrete mixer, a garbage truck, a fire 

11 truck, a dump truck. They just aren't aerodynamic, nor 

12 do they normally drive in conditions where the 

13 aerodynamics -- you're going to that from aerodynamics. 

14 The places I would see that you could do some 

15 gaining from would be, for instance, a garbage packer, 

16 which runs hydraulics all day long to do the -- you

17 know, the automated side loader, the forks, all of 

18 that. Hydraulics takes energy, right? And there's

19 some potential, I think, from an engineering standpoint 

20 to improve on those -- in those areas. But I don't

21 know how you measure it. I don't how you measure it, 

22 how you do that consistently between manufacturers,
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1 between designs. 

2 And one of the struggles is that if you look at 

3 the number of, say, refuse trucks built in a year, 

4 there's about 6,000. You divide that by the number of 

5 manufacturers out there, which is probably eight or

6 nine. You're down to looking at little groups of a

7 thousand trucks a piece. Concrete mixers are even 

8 worse. Fire trucks are worse than that. There's like 

9 3,000 fire trucks built a year, custom fire trucks, and 

10 there's eight manufacturers. 

11 So the technology, the study, the testing, all of 

12 that to carve out little bits of improvement here or 

13 there in vocational truck design where the -- where the 

14 volumes are so low, that's where I think is one of the 

15 -- is one of the real struggles. If we were building, 

16 you know, 100,000 a year, you could put a lot of 

17 engineers behind it and maybe do something. But that's 

18 one of the struggles. 

19 MR. GRUNDLER: Thank you. And I think we are -- 

20 we tried to be sensitive to those questions, and we do 

21 see the differences in these categories, and I don't 

22 think we're expecting a lot of aero improvement in 
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1 vocational. But let me turn to my other panel members. 

2 MS. BRAKORA: I can speak a little bit to the 

3 vocational. I think for the emergency vehicles, there 

4 is -- the proposal does say just to have tire -- low 

5 rolling resistance tires, so they wouldn't have the

6 other checkboxes. It's pretty much a carryover of the 

7 Phase 1 proposal. 

8 And I do think that they're requesting a comment 

9 on what an appropriate threshold would be for a small 

10 volume exemption for vocational vehicles, specific 

11 manufacturers that don’t make a high volume of 

12 vehicles. We do have small business exemptions, which 

13 is employee based, but we're also requesting comment on 

14 whether a volume exemption is appropriate. 

15 MR. GRUNDLER: Yeah, that's great. And I want to 

16 make sure you understand that we're all for energy 

17 conservation and reducing greenhouse gases. And if

18 there's ways that we can take this vocational market 

19 and find good ways to do that and be compliant, we'd 

20 like to work with people on that. 

21 And I would reflect the trailer guys in saying

22 that I think it would be good to have a little bit more 
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1 time that we can work back and forth. And if there's 

2 any to push off the timeline and allow people to do

3 that and really get into the nuts and bolts of this

4 thing, I think that would be of benefit. 

5 MR. SILVERMAN: I would add, by the way, that June 

6 19th is when we posted this electronically. So saying 

7 there's a 60-day comment period we think is a little 

8 bit of a misnomer. 

9 MR. FREILER: If you check my testimony, I did say 

10 a bit over 60 days. I am aware that there was both a 

11 seven-day extension and a pre-publication version. And 

12 we appreciate all the information. There was actually 

13 a great deal of information from the EPA and the Ann 

14 Arbor branch on the proposals and the thoughts of where 

15 this rule was going. Admittedly, you know, we really 

16 needed to see the details to be able to start forming 

17 anything on that. 

18 But we greatly appreciate the outreach of both

19 Administrations to our group so that we could do this, 

20 and the work of the Small Business Administration. 

21 It's all been very helpful, and we hope that you found 

22 our input helpful. 
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1 MR. GRUNDLER: Any other questions? 

2 MR. LACKORE: Yeah, ditto. We like working with 

3 you guys. We think you're a pretty competent group. 

4 I'm not trying to be -- 

5 MR. GRUNDLER: Make sure the court reporter got 

6 that. 

7 (Laughter.) 

8 MS. BRAKORA: John, to your extension request,

9 were you requesting 90 days additional on top of the 

10 60, or 90 days total? 

11 MR. FREILER: On top of the 60, and that is what 

12 we were looking for, so that would take us back to 

13 around the end of the year. 

14 MS. BRAKORA: Thank you. 

15 MR. GRUNDLER: No more questions? Thank you so 

16 much for your time and travel here. Thank you. 

17 MR. FREILER: Thank you. 

18 MR. GRUNDLER: Panel seven, come on down. 

19 MR. TAMM: And while panel seven is coming to the 

20 main table, again, for any that have come in since this 

21 morning's announcement, we do have a staging area over 

22 here on your right-hand side up front, so we would 
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1 invite the next panel to come down. There have been a 

2 couple of changes in the people on the panel just 

3 because of changes in who's here to testify. 

4 So panel eight, we have Tom Conway, Christopher 

5 Johnson, Bill Mammen, Alexander Barton, John McNicols, 

6 and Terrence Gallagher. 

7 Okay. And as we have the current panel in place, 

8 Mr. Kunkel, if you'd like to begin? 

9 MR. KUNKEL: Good afternoon. Thank you for 

10 allowing me the opportunity to testify before you on 

11 the proposed standards for the new EPA regulations on 

12 medium and heavy duty truck greenhouse gas emissions 

13 and fuel efficiency standards. My name is Glenn 

14 Kunkel, and I'm a veteran of the United States Marine 

15 Corps, and a member of Operation Free, a nationwide

16 coalition of thousands of veterans that advocate for 

17 securing America with clean energy. 

18 I applaud the Obama Administration for proposing 

19 standards that will make our trucks cleaner and more 

20 efficient. I joined the military because I care deeply 

21 about our Nation's security and stability, and I am

22 here today because along with the consensus of senior 
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1 military and national security experts, I believe that 

2 we face a serious threat to our national security, and 

3 that is a dependency on oil. 

4 During my service in Iraq as an advisor to the

5 Iraqi army, the logistics of fuel consumption were 

6 pivotal to our capabilities and security posture. The 

7 nature of the vehicles needed to establish tactical

8 dominance were inefficient for sustained operations in 

9 any environment, let alone ones that are decidedly 

10 hostile. 

11 This parallels the economic necessities of our

12 Nation in that such a vast portion of goods are 

13 transported by truck. Just as we took numerous steps 

14 in Iraq to conserve and stretch our resources in order 

15 to accomplish our mission, similar steps should be 

16 taken to preserve and bolster the transportation 

17 industry's efficiency to the point that our economic 

18 stability is less threatened. 

19 By mitigating our consumption of petroleum-based 

20 fuels, we also mitigate a number of disruptions to our 

21 domestic security and stability, such as the amount of 

22 CO2 that is dispersed into the atmosphere and the 
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1 resulting disruptions caused by severe weather 

2 patterns. Furthermore, reducing fuel consumption will 

3 also address the challenge of globally capable 

4 extremist groups that often profit from petroleum 

5 revenues. Most importantly, I believe that a cleaner, 

6 more sustainable and efficient United States is going 

7 to have to be established in order to maintain our 

8 current global posture, both in security capabilities 

9 as well as economic stability. 

10 Although trucks are only seven percent of the 

11 total number of vehicles on the roads, they consume 25 

12 percent of the fuel. This marks a significant percent 

13 of emissions relative to the number of trucks on the 

14 road. With these new regulations, we'll save 

15 approximately 1.8 billion barrels of oil over the 

16 lifetime of the vehicles on the road, and it's an 

17 important step in combatting our oil dependency. 

18 Currently, oil is essential for the military to 

19 defend us. Everything from tanks to fighter jets to 

20 HUMVEES use oil, and delivering it on the battlefield 

21 is a dangerous job. In Afghanistan, one in every 24 

22 fuel convoys results in a casualty. Oil trade routes 
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1 are slow, they're scheduled, they're frequent, and this 

2 makes them very easy targets for enemy forces. 

3 These rules benefit the military because trucks 

4 won't have to refuel as frequently, which can be 

5 dangerous and costly in combat environments. 

6 Additionally, too much of our money for oil ends up in 

7 the hands of hostile countries and extremist fighters. 

8 There are economic problems with oil, too. The 

9 global supply cannot keep up with demand. The price 

10 will keep going up, hitting all of us at the pump. 

11 With this rule, vehicle owners will save an average of 

12 $170 billion in fuel costs over the lifetime of their 

13 vehicles. 

14 Increasing truck efficiency saves money, which

15 will be reflected in the price of consumer goods. 

16 Furthermore, when the price of oil spikes, the military 

17 must repurpose funds away from training, maintenance, 

18 and other mission readiness programs to offset that

19 cost, putting our security posture at risk. 

20 Additionally, the use of fossil fuels increases the

21 likelihood of more troops sent into harm's way. As the 

22 Department of Defense's recent report on "National 
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1 Security Implications of Climate-Related Risks and the 

2 Changing Climate" affirms, climate change is widely

3 recognized as a threat multiplier. Frequent and severe 

4 weather events destabilize some of the world's most

5 dangerous regions, and this exacerbates existing 

6 national security threats by pushing already unstable 

7 states to near cost in crisis. 

8 At this point, the United States is requested to 

9 respond to disasters every two weeks, a number likely 

10 to increase as the impacts of climate change become

11 more acute. While these new EPA regulations make great 

12 strides to mitigate the impacts of carbon and 

13 emissions, such as reducing greenhouse gas emissions, 

14 by one billion metric tons over the life of the 

15 vehicles on the road, we must take further measures to 

16 reduce our oil dependency in the interest of national 

17 security. 

18 Analysis shows that with modern engineering 

19 capabilities, stronger standards could reduce trucks' 

20 fuel use by up to 40 percent by 2025. Continued 

21 progress in environmental standards made by the EPA are 

22 vital to the well-being of our Nation as well as the 
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1 global community. In raising our greenhouse gas 

2 emissions and fuel efficiency, we strengthen our 

3 national security by supporting the U.S. economy, 

4 increasing global stability, and sending fewer of our 

5 men and women into harm's way. 

6 Once again, I applaud the EPA for their efforts, 

7 and I thank you very much for the opportunity to 

8 testify today. 

9 MR. TAMM: Mr. Kunkel, thank you very much for

10 your testimony, and, in particular, thank you very much 

11 for your service to the country. 

12 MR. KUNKEL: My pleasure, sir. 

13 MR. TAMM: Mr. Stuckey. 

14 MR. STUCKEY: Thank you. My name is Richard 

15 Stuckey. I'm a retired partner with Accenture, IT 

16 consulting company, and a volunteer member of the 

17 Sierra Club, and UCS, and various environmental 

18 organizations. But I'm speaking just as myself 

19 personally with my family today. 

20 First of all, I’d like to commend the EPA for the 

21 outstanding work you've done with regulations on the 

22 variety of different areas impacting climate change, 
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1 pollution, and so on. And they're going to have very 

2 significant benefits to the economy, health, the 

3 environment, and help, as my colleague just said, to 

4 reduce our dependency upon fossil fuels. 

5 It is particularly important that the U.S. shows 

6 this kind of leadership as we head towards Paris for 

7 the negotiations coming later in the year. If we 

8 hadn't shown this kind of leadership, on one would 

9 believe anything we had to say. 

10 I had the pleasure of testifying back in November 

11 2010 when you had the Phase 1 hearings here, and 

12 appreciate the Phase 1 results came out extremely 

13 favorably. And I appreciate also the work you've done 

14 to -- in Phase 2 and endorse the rules you've come up 

15 with. 

16 From a personal point of view, I live fairly close 

17 to expressways. I have a couple of daughters who both 

18 suffered from breathing problems in Chicago due to the 

19 polluted air, and a large part of that coming from duty 

20 trucks, a major contributor of pollution. And the 

21 regulations you've proposed will let my daughters and 

22 others who suffer from breathing problems live better 
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1 and healthier lives. So thank you for that. 

2 According to the ICCT, heavy duty trucks in the 

3 U.S. make up only five percent of vehicles on the road, 

4 but generate more than 30 percent of carbon dioxide

5 emissions. And they're responsible for more than 36 

6 percent of particulate emissions, some of which you

7 will have addressed in Phase 1 I know. 

8 And you've heard from many speakers how important 

9 the changes will be from the Phase 2 rules savings 

10 $550,000 barrels of oil a day, 120 million metric tons 

11 of global pollution, the equivalent of all the 

12 emissions from U.S. homes for a whole year. So this is 

13 extremely important. These benefits are huge, but so 

14 are the problems we're facing. 

15 And so, it's essential that we question both 

16 whether the changes go far enough and also if they go 

17 fast enough. And unfortunately even with the proposed 

18 Phase 2 regulations, fuel usage from heavy duty trucks 

19 is expected to increase and will exceed the levels in 

20 2013 for the future, and so, we aren't achieving all 

21 the results we'd like to get. 

22 Studies show that the technologies that are needed 
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1 to achieve a 40 percent reduction in fuel consumption 

2 can be incorporated in new trucks by 2025 rather than 

3 2027, and those will save an additional 200,000 barrels 

4 of oil a day in 2035, and avoid 40 million metric tons 

5 of global pollution annually as we've heard before, an 

6 equivalent to shutting down 12 coal-fired power plants. 

7 So I think we have to do everything we possibly 

8 can to look and see whether we can accelerate the 

9 changes that you have proposed. And from everything I 

10 can see, the technology necessary to do that is readily 

11 available and already in use in Europe and elsewhere. 

12 I'm by no means an expert in this area, but as I 

13 walked around Chicago this morning prior to coming in 

14 here, I noticed a large number of garbage trucks doing 

15 their rounds and also school buses sitting outside the 

16 schools. And these vehicles spend most of their time 

17 doing their most productive work -- or some of them

18 anyhow -- sitting idle and doing no miles per gallon. 

19 And I'm concerned, although I haven't read the details 

20 in your proposal, that a proposal to improve the 

21 emissions by looking at their miles per gallon is not 

22 going to get the kind of results that we need. We need 
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1 to be looking at how we can reduce their consumption 

2 when they're doing zero miles per gallon because a 

3 large part of their time is spent doing zero miles per 

4 gallon even when they're productive, like loading 

5 garbage. 

6 So maybe we can look into how you specify that and 

7 say to the auto stop -- you know, because a lot of 

8 troubles that the drivers only would get air 

9 conditioner in their cabs when they keep this, you 

10 know, 600-horsepower running. And that is really not 

11 necessary, can divert that to a smaller motor or do the 

12 hydraulics in a different manner. So maybe you do 

13 address this, but I have not found that so far. 

14 So as the EPA did when you issued your final power 

15 regulations, you made significant improvements from

16 what in the draft, I hope you'll be able to do the same 

17 things with these proposals as well. Thank you for the 

18 time to testify. 

19 MR. TAMM: Okay. Thank you for your comments. 

20 Maybe I could offer one really quick response for 

21 vocational vehicles, things like garbage trucks. They 

22 are broken up into different use categories, and the 
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1 intent was to recognize things like the amount of idle 

2 time, so there is a low speed segment built into the 

3 proposal. But we do seek comment -- 

4 MR. SILVERMAN: (Off audio.) 

5 MR. STUCKEY: Yeah, okay. Thank you. 

6 MR. TAMM: But we do -- we're open to comments on 

7 did we get that right, of course. So thank you for

8 your comments. Mr. Richardson? 

9 MR. RICHARDSON: Good afternoon. My name is 

10 Shannon Richardson, and I'm an engineer with XL 

11 Specialized Trailers, and we're located in Manchester, 

12 Iowa. I'll start out by disclaiming that even though 

13 my comments will pertain to both exclusions and 

14 adaptations as specific areas of this proposed 

15 regulation, in no way should they be construed as 

16 support for this GHG Phase 2 standard as it applies to 

17 the truck/trailer industry. 

18 Being good stewards of our surroundings and being 

19 maintaining vigilance to our impact on our environment 

20 is a high priority for us. But we believe it should be 

21 through voluntary acceptance of proven technology and 

22 techniques working well -- working with well thought 
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1 out regulations that will make a positive impact, and 

2 not through generic applied rules that attempts to 

3 create a package of a one-size-fits-all. 

4 XL Specialized Trailers is a small business entity 

5 that manufacturers custom built-to-order heavy haul low 

6 beds, step deck, and flatbed trailer. As such, we do 

7 not have a large team of dedicated personnel to read, 

8 understand, and comment on all aspects of this proposed 

9 regulation, much less just the basic information that 

10 only applies -- only applies to the truck/trailer 

11 industry. Basically I am that team. 

12 XL Specialized Trailers would like to thank the 

13 regulatory Agencies for working with Truck Trailer 

14 Manufacturers Association, TTMA, which XL is a member 

15 of, over the past year and a half during the agencies' 

16 initial consideration of this proposal. It's apparent 

17 that some of our fingerprints are found within this

18 document. 

19 However, this proposed rulemaking is exceptionally 

20 involved for our industry, and to help ensure the best 

21 opportunity for comments and assist in the crafting of 

22 the proposed regulation, XL Specialized Trailers is
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1 officially requesting a 90-day minimum, ideally six2 month extension to the now September 17th, 2015 

3 deadline for comments period. TTMA has petitioned EPA 

4 to extend the comment period beyond that original date 

5 of September 11th, 2015, and as a member, XL 

6 Specialized Trailers is in full support of this 

7 petition. 

8 This regulation as it pertains to the 

9 truck/trailer industry proposes to separate trailers 

10 into 10 subcategories. Of these subcategories, I’d

11 like to address the area of non-box trailers, more 

12 specifically trailers that would unofficially be 

13 classified as specialized heavy haul trailers. 

14 As the current proposed regulations are presented, 

15 a very small list of exclusions and less stringent 

16 standards are laid out. We appreciate the regulatory 

17 agencies' proposal allowing of this list, but we ask 

18 the agencies to also consider a much broader breakdown 

19 to a specific characteristic of what defines a heavy 

20 haul trailer. Most of these trailers are not intended 

21 nor are they used for over the highway long haul 

22 operations or at highway speeds for extended periods of 
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1 time. 

2 These trailers will operate both on and off road 

3 at various speeds and in various terrains. There is 

4 not specific design characteristics that indicate that 

5 this trailer should operate at low speeds on a specific 

6 type of train, but there are physical characteristics 

7 that can distinguish heavy haul style trailers from

8 other trailer types. 

9 Heavy haul style trailers are designed to carry 

10 equipment used for construction, agriculture, mining, 

11 logging, power generation, and other industries, 

12 specialized loads generally not transported on a 

13 regular basis, high center gravity loads, and oversized 

14 length, width, height, and/or weight loads. Generally 

15 speaking, the trailer is a tool to move the primary

16 pieces of equipment which is then used as a primary

17 revenue generator for the end user. 

18 Most of these trailers operate in very small 

19 fleets of a few trailers for a single tractor, or are 

20 owner operated where requirements for specific 

21 mandatory design standards for tires and specialty 

22 equipment types would cause a larger financial burden 
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1 than the perceived benefit of reduced fuel use. This 

2 definition list will be submitted as a written comment, 

3 and we are asking the agencies to seriously consider 

4 this while developing the language for this regulation. 

5 As a small business entity, XL Specialized 

6 Trailers must consider the potential burden imposed on 

7 us by the proposed regulations. Additional pre8 production reporting, new compliance and equipment 

9 labeling, government mandated warranty requirements not 

10 normally seen in this industry, user manual equipment 

11 requirements, compliance submissions and record 

12 keeping, will create additional burdens to an already 

13 cost sensitive industry. As the proposed regulations 

14 are presented, this burden will exist whether a company 

15 produces a fee regulated product or many. 

16 The truck/trailer industry is a very innovative 

17 industry that embraces new technologies and standards 

18 that enhances the efficient operation of our equipment 

19 as well as leading to a safer product. Mandating the 

20 implementations of this type of regulation across the 

21 board creates a counter productive environment that

22 leads to subpar products that end up costing consumers 
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1 more and not achieving the goals set out by the 

2 regulatory agencies. 

3 In closing, I would ask the agencies to consider 

4 the items I presented and will present as written 

5 comments during the rule writing phase of this process. 

6 Thank you for your time and the opportunity to speak 

7 during this public hearing. I am able to take 

8 questions you may have now, and will be available for 

9 questions that you may have in the future. Thanks.

10 MR. TAMM: Okay. Thank you very much. Mr. Cohn? 

11 MR. COHN: Good afternoon. My name is Al Cohn, 

12 director of new market development and engineering 

13 support for Pressure Systems International, better 

14 known as PSI, which is the global innovator behind 

15 automatic tire inflation systems, more commonly known 

16 as ATIS. My interest in presenting at this hearing is 

17 to address the definition of an automatic tire 

18 inflation system and the requirements of a "qualified 

19 ATIS system." 

20 Our company invented our automatic tire inflation 

21 system 22 years ago and market it globally. In North 

22 America, we market it under the Meritor brand name, the 
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1 Meritor Tire Inflation System by PSI. Commercial 

2 trailer tires receive the least amount of maintenance 

3 on commercial tractor trailer combinations. Today we 

4 estimate that approximately half of the commercial 

5 trailers being produced in North America have some type 

6 of tire solution with the overwhelming majority being 

7 ATIS. We also estimate that over one million trailers 

8 are currently running with ATIS today. 

9 The benefits of ATIS include increasing fuel 

10 economy, reducing greenhouse gas emissions, and 

11 significantly reducing tire and safety related roadside 

12 service calls. It also dramatically reduces road 

13 debris from tire casings and better utilization of 

14 casings for retreads for lower oil consumption by the 

15 tire manufacturers. A typical return on investment is 

16 well under 12 months. 

17 The basic principle of ATIS is to ensure that 

18 tires maintain a minimum specified tire pressure as

19 determined by the fleet. However, there are numerous 

20 tire solutions in the market today, and there are 

21 operational characteristics between some of those that 

22 classify themselves under the ATIS heading. With most 
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1 ATIS systems, air is automatically added whenever an 

2 individual tire pressure below the system setting 

3 either while the trailer is in a static or dynamic 

4 state. 

5 I wish to clarify two very important items in the 

6 proposed rulemaking: the definition of "automatic tire 

7 inflation system" listed in Subpart 1. Definitions and 

8 other reference information is not consistent with the 

9 historical industry definitions. TMC, the Technology 

10 Maintenance Council of the American Trucking 

11 Association, in their recommended practice, RP-239(a), 

12 most recently updated in 2014, uses the following 

13 widely-accepted definition of ATIS, and I quote: 

14 "Automatic tire inflation system maintain tire pressure 

15 at a single preset level, and are pneumatically or 

16 electronically activated. A warning lamp indicates to 

17 the driver that the system has been activated, and air 

18 is being added to a tire. These systems eliminate the 

19 need to manually inflate tires." 

20 The current definition included in the proposed 

21 rulemaking states, and, again, I quote, "ATIS means a 

22 system installed on a vehicle to keep each tire 
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1 inflated to within 10 percent of the target value with 

2 no operator input." Assigning an arbitrary number of 

3 10 percent is not consistent with the laws of tire 

4 physics. Tire pressures increase by 15 to 20 percent 

5 when the tire is hot and running on a fully loaded 

6 vehicle at 75 miles an hour on an asphalt road on a

7 sunny day. Tires will cool back down to the specified 

8 tire pressure after several hours depending on the size 

9 type tire. 

10 The issue with tires and reduced fuel economy and 

11 increased greenhouse gas emissions is because of tire 

12 under inflation. ATIS systems assure that tires will 

13 always be running at the recommended cold tire 

14 inflation pressure. 

15 The second issue to address is a clarification

16 regarding "qualified automatic tire inflation systems." 

17 Section 1037.107, Emissions Standards for Trailers, of 

18 the proposed rulemaking, discusses the use of low 

19 rolling resistance tires, and that qualified automatic 

20 tire inflation systems are required on non-box trailers 

21 effective model year 2018. It is our recommendation 

22 that the term "qualified" be expanded. 
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1 SAE Recommended Practice J2848-2, dated June 2011, 

2 is an RP on the subject of automatic tire inflation

3 systems. It is the industry standard that details the 

4 basic operational requirements for any automatic tire 

5 inflation system. This RP should be referenced in the 

6 proposed rulemaking when qualified automatic tire 

7 inflation systems are discussed. 

8 Thank you very much for allowing me to address

9 this group today, and we'll be happy to entertain any 

10 questions or comments. Thank you very much. 

11 MR. TAMM: And, again, thank you for your 

12 comments. Mr. Grenerth? 

13 MR. GRENERTH: Well, my name is Scott Grenerth. 

14 I'm the director of regulatory affairs for the Owner15 Operator Independent Drivers Association. However, to 

16 keep it short, OOIDA. And OOIDA represents over 

17 150,000 small business truckers and professional 

18 drivers. And if you look out there on the road today, 

19 more than 90 percent of the people out there driving 

20 for carriers and the carriers themselves are small 

21 businesses, six or less. Fully half of the number of 

22 carriers out there are one truck operations, just a
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1 single person. 

2 So until a year ago, I was an owner-operator just 

3 like the members I now represent. And I have a feeling 

4 I'm probably the only person here who has actually 

5 purchased and driven one of these trucks you're talking 

6 about regulating, so I’d be thrilled to be found 

7 differently on that. And I have a feeling that has to 

8 do with the location we're at today, so I'll get a bit 

9 in more that later. But to say it least, we are 

10 certainly representing people who have real world 

11 experience dealing with the regulations that come down. 

12 Fuel is definitely a trucker's highest cost. 

13 There's no denying that. The success of a business

14 depends upon them getting fuel economy, and it is truly 

15 a make it or break it type of a proposition. You can 

16 be run out of business if you're not watching your fuel 

17 costs and managing that well. And because of that,

18 there already are a number of technologies out there 

19 that being adopted and used throughout the industry

20 from the smallest people on up to the largest of 

21 fleets. 

22 We appreciate the engagement that we have seen
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1 from the agencies, and particularly I give a nod to EPA 

2 on this with listening to our perspective, listening to 

3 our membership, and I think also, as we've heard today, 

4 listening to the industry in the broadest sense 

5 possible. And while we do feel that the experience of 

6 our -- of the owner-operators out there in our 

7 membership, their viewpoint is being reflected 

8 throughout the proposal, we do continue to have 

9 concerns. And as the end users of these products that 

10 are going to be regulated, we need to make sure that 

11 this is a cost-effective and reliable product that 

12 comes out of this because our members have the 

13 potential to see the benefits from this rulemaking, but 

14 they also can be significantly harmed if it is not done 

15 correctly. We need the agencies to continue their 

16 engagement and ensure the success of this rulemaking 

17 for everyone concerned. 

18 Regarding the levels of stringency and the 

19 proposed alternatives for the tractor, the trailers, 

20 and the engines, the timelines for the preferred 

21 alternatives do call into question the ability of the 

22 OEMs to develop the technologies that will be required 
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1 in order to maximize the reliability and keep the costs 

2 in check. We have heard that multiple times today as 

3 the agencies have very wisely noted. While the 

4 alternatives with a shorter lead time may seem enticing 

5 with their promised benefits to the environment, there 

6 are serious concerns about the feasibility of shorter 

7 lead times. If the lead times are not sufficient, a 

8 serious problem will develop, and we can guarantee 

9 that. 

10 There is already a tremendous amount of very well11 earned distrust from the results of previous emissions 

12 regulations, which led to very, and I mean very, 

13 widespread problems with reliability and high cost. 

14 Our members continue to be impacted by those issues

15 every single day, and this absolutely can include and 

16 has included people who have been completely driven out 

17 of business because of the fact of no fault of their 

18 own. Just trucks that are not reliable enough to keep 

19 on the road and keep earning money. 

20 So reliability and cost do go hand in hand, but 

21 cost is a special focus for small businesses. Those 

22 people have already seen the price of a new truck rise 
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1 by tens of thousands of dollars due to the existing

2 regulations on emissions and from Phase 1. No matter 

3 how efficient a vehicle is, if the price is 

4 unattainable for a small business trucker, they are

5 much less likely to be able to purchase that vehicle. 

6 OOIDA has seen that because we do survey our members 

7 very regularly to keep on this, so we have accurate

8 information. We have less than 20 percent of our 

9 members currently considering purchasing new trucks

10 today. Compare that to a decade ago it was 50 percent, 

11 and that is what has resulted from this issue. 

12 So both issues -- the reliability and the price -- 

13 have the potential to wipe out the promised benefits of 

14 this rulemaking. Keeping the level of stringency 

15 attainable is crucial. Political appearances of being 

16 tough about greenhouse gas emissions certainly can 

17 sound good; however, the only way to actually get real 

18 world results to benefit generations to come is through 

19 a rulemaking which leads to vehicles that truckers want 

20 to purchase and, and really important here, and they 

21 can afford to purchase. 

22 We urge the agencies to continue to hear the 
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1 concerns of small business truckers and to incorporate 

2 these concerns into the rulemaking. With that in mind, 

3 and you've heard this already several times today, we 

4 urge the agencies to extend the comment period by an 

5 additional 90 days and hold a third hearing at a 

6 location where truckers actually are and where they

7 would be able to park and attend. So not here, in 

8 other words. 

9 And because we want -- OOIDA wants -- our members 

10 want to drive fuel efficient and reliable trucks that 

11 are reasonably priced, and a rule that helps that 

12 happen is something that will work for every single

13 person represented in this room today. Thank you. 

14 MR. TAMM: And thank you for your testimony. Mr. 

15 Brubaker. 

16 MR. BRUBAKER: Good afternoon. My name is Kevin 

17 Brubaker. I'm the deputy director of the Environmental 

18 Law and Policy Center, and I serve on the U.S. 

19 Department of Treasury's National Freight Advisory 

20 Committee. I'm speaking today on behalf of the 

21 Environmental Law and Policy Center, a Chicago-based 

22 not-for-profit organization dedicated to the principle 
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1 that environmental protection and economic growth are 

2 mutually compatible goals. 

3 The proposed regulations for heavy truck vehicular 

4 fuel economy exemplify this belief. If promulgated, 

5 the regulations will reduce air pollution and save 

6 fuel, a win-win for the environment and for truckers' 

7 wallets. These benefits are particularly important

8 here in Chicago, the center of America's transportation 

9 networks. Between a quarter and a third of all freight 

10 movements in the United States come through Chicago. 

11 Two-thirds of those freight movements occur on truck, 

12 so we have a strong vested interest in this proposal. 

13 We urge the EPA to strengthen and adopt these 

14 regulations. 

15 In the interest of time, let me make four simple 

16 points. First, these regulations would protect public 

17 health and the environment. The proposed regulations 

18 would reduce nitrous oxide emissions by 2.4 million

19 tons over the lifetime of vehicles subject to these

20 standards from phases one and two of this regime. They 

21 would reduce greenhouse gas pollution by a billion 

22 metric tons. They would save over a thousand lives
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1 each year. 

2 Second, because trucks consume so much fuel, this 

3 regulation is cost-effective. Paying a little more now 

4 for a more fuel efficient truck will result in huge

5 savings at the pump. In fact, tractor trailer owners 

6 can repay their costs and start earning money on this 

7 investment in just two years. Overall, the new 

8 regulations are expected to save society $230 billion 

9 over the life of this program. And when truckers are 

10 buying 75 billion less gallons of diesel fuel, that

11 money is available to spend on other things that 

12 strengthen our domestic and local economies. 

13 Third, the proposed regulation does not go far

14 enough. Analysis from EPA, California, and 

15 manufacturers demonstrate that cost-effective 

16 technologies are currently available to achieve at 

17 least a 15 percent improvement in engine efficiency, 

18 more than three times greater than that which is 

19 reflected in EPA's current proposal. Similarly, the 

20 proposal -- the proposed regulation ignores fuel 

21 efficiencies that could be achieved through aerodynamic 

22 improvements to trailers. And lastly, these 
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1 regulations should be fully implemented by 2024 rather 

2 than 2027 as proposed. My understanding is that EPA's 

3 own analysis shows that this deadline is achievable. 

4 More importantly, car and truck technology is 

5 changing with incredible speed. From the time of Henry 

6 Ford's Model T to about 2010, we had essentially two 

7 kinds of engines: gasoline and diesel. Today we're 

8 seeing an explosion of innovation with hybrid electric, 

9 fully electric, hydrogen, compressed natural gas, and 

10 other technologies entering the marketplace. 

11 Delaying the final phase-in of today's rule to

12 2027 means we won't be able to respond to any of these 

13 changes until at least 2030. Faster implementation of 

14 today's rule means flexibility to respond sooner to

15 tomorrow's opportunities. 

16 Fourth and finally, the proposed regulation should 

17 do more to protect children's health. Asthma 

18 hospitalization rates in Chicago are nearly double 

19 those of the national average, and that's why we're so 

20 concerned that the proposed rule would actually 

21 increase particulate pollution by encouraging the use 

22 of auxiliary power units on trucks. We urge you to
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1 amend this rule by requiring that these units be 

2 equipped with particulate filters. This would 

3 eliminate the long-term increase in particulate 

4 pollution which may occur as a result of these 

5 regulations. 

6 In conclusion, we commend the Environmental 

7 Protection Agency for proposing this rule. Thanks to 

8 current regulations, automobile drivers enjoy better 

9 cars that save money at the pump. It's time for 

10 truckers to enjoy these benefits as well. Thank you. 

11 MR. TAMM: Okay. And thank you as well for your 

12 comments. So do we have questions of the panel? 

13 MR. GRUNDLER: Yeah. Mr. Grenerth, thank you for 

14 your testimony, and we, of course, did not expect many 

15 independent truckers to be able to park out on Monroe 

16 Street. We are hopeful, however, that at our next 

17 hearing in Long Beach that that might be a little bit 

18 more convenient for some of your members, and hope to 

19 see more of them there. 

20 MR. GRENERTH: We're trying on our end to make it 

21 possible, and appreciate any assistance you can give. 

22 MR. GRUNDLER: Okay, thank you. 
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1 MR. TROWBRIDGE: If I could, Mr. Grenerth, I thank 

2 you also for your testimony. It seems to me a fairly 

3 crucial portion of what you're asking us to consider 

4 here is the question of whether the upfront costs of 

5 these additional technologies are so great that we 

6 wouldn't see the benefits that we're seeking because 

7 your members wouldn't be able to purchase trucks with 

8 these technologies. 

9 Is it you contention that we're wrong about the 

10 payback periods for some of these technologies, or is 

11 it that a two-year payback period for a new truck is 

12 too long for your members to be able to really make the 

13 decision to make that purchase based on a two-year 

14 payback period? 

15 MR. GRENERTH: First, I'll say you're absolutely 

16 correct. Payback is great, but first you have to pay 

17 for it, so to put it real simply. And secondly, that 

18 the area of concern comes primarily from the fact that 

19 in previous regulations, the cost has far exceeded what 

20 it was supposed to be according to, you know, the 

21 analysis. You know, there was a pretty good history of 

22 that unfortunately. And, you know, in this case I feel 
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1 like we're a little bit closer to reality perhaps on 

2 that because we know some of these things definitely do 

3 work, you know, as I mentioned. They're already widely 

4 adopted by many fleets and small business owners. 

5 But it's just the combination of making sure that 

6 -- as you've heard already today from other people that 

7 -- you get it right as far as you know, where 

8 specifically these things are mandated so that they

9 will actually be a benefit and not just a cost that

10 doesn't give a return. 

11 And, then again, the bigger concern that his -- I 

12 feel it's the closest thing that you all have perhaps 

13 kind of ignored a bit too much overall is the job that 

14 has been done in listening to other areas. The 

15 maintenance costs, you know, of the technology because, 

16 again, that's why I referenced -- that is what has 

17 killed so many of our members is the maintenance on

18 these things. It's great improved technology, but 

19 pushing it too far too fast too soon can lead to having 

20 breakdowns. And warranties only go so far, you know. 

21 While it's great to know that something is under 

22 warranty, if you're not earning any money during the 
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1 time when it's being repaired, and that can take days 

2 in some cases. Parts right now for many emissions3 related items can take days to arrive, and we've had 

4 one of our members who -- she was sitting in a hotel so 

5 long she finally went home -- back up to Canada 

6 actually because they said it's going to be a few more 

7 days before we get this repaired. And it was an 

8 emissions-related item. 

9 MR. TROWBRIDGE: Thanks. 

10 MR. GRENERTH: Sure. 

11 MR. GRUNDLER: Thank you again for those comments. 

12 And I want to assure you we're not ignoring the 

13 maintenance costs. We have included them. But we, of 

14 course, you know, would welcome information if we need 

15 to adjust them or didn't have them right. 

16 MR. GRENERTH: Right. 

17 MR. TAMM: Okay. If there are no other questions 

18 from the panel, thank you very much for your comments. 

19 And we'll ask the group that's in the staging area to 

20 move forward. 

21 MR. GRUNDLER: I also want to make an announcement 

22 that if you're in the audience and are hoping to 
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1 testify but didn't sign in, please do so so we can keep 

2 track of who's here and call you up. 

3 So welcome panel eight. We'd like to also ask

4 panel nine to move over to the staging area, panel nine 

5 being Pat Walter, Gwen McElhattan, Hannah Gutierrez, 

6 Korbin Houston, Barry McCabe, Hannah Flynn, and Don

7 Schaeffer. Mr. Conway, proceed when you're ready. 

8 Welcome. 

9 MR. CONWAY: Good afternoon. I'm Tom Conway, 

10 regional manager at the Blue Green Alliance. Thank you 

11 for the opportunity to make comments on behalf of the 

12 Blue Green Alliance on the U.S. Environmental 

13 Protection Agency and the National Highway Traffic 

14 Safety Administration's proposed Phase 2 standards for 

15 medium and heavy duty vehicles. 

16 These standards will increase fuel efficiency and 

17 cut greenhouse gas emissions from long haul trucks,

18 along with full-sized pickups, other trucks, buses, and 

19 vocational vehicles. These standards can continue 

20 America's auto and manufacturing resurgence. 

21 The Blue Green Alliance is a national partnership 

22 of America's largest labor unions and environmental
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1 organizations. We work together to turn today's 

2 biggest environmental challenges into our biggest 

3 economic and job creating opportunities. Together with 

4 15 million members and supporters, we are a powerful 

5 unified voice calling for good family sustaining job, a 

6 clean environment, and a thriving and fair American

7 economy. 

8 The Blue Green Alliance and its 15 labor and 

9 environmental partners recognize the importance of the 

10 proposed rule. America's economy depends on leadership 

11 in building the next generation of clean, globally12 competitive energy and vehicle technology. These new 

13 standards can provide a critical opportunity to save 

14 jobs, further reduce the pollution driving climate and 

15 foreign dependence, while enhancing the competitiveness 

16 of U.S. manufactured trucks and global markets. 

17 For the past decade, the auto industry and the

18 light, medium, and heavy duty sectors, and American

19 workers represented by the United Auto Workers, and

20 United Steel Workers, and others, have been on the 

21 front lines when it comes to rebuilding manufacturing 

22 jobs and building the world-leading technology needed 
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1 to achieve deep cuts in carbon pollution and save 

2 consumers billions at the pump. Soon to be released 

3 research carried out by several of our partners finds 

4 that more than 380 plants that are manufacturing fuel 

5 efficient medium or heavy duty vehicles or their 

6 components today in states all across the country. 

7 Done right, the standards can spur investment, secure 

8 and grow jobs, and enhance U.S. competiveness across 

9 these businesses and technologies in the industry as a 

10 whole. 

11 We greatly appreciate the thorough and systematic 

12 process EPA and NHTSA have undertaken in developing the 

13 proposal. It is critical that an effective final rule 

14 works for the environment, for the economy, and for the 

15 thousands of hardworking American men and women in the 

16 heavy truck component and related industries. We urge 

17 the agencies to continue their thorough and deliberate 

18 process. 

19 Together the previous rounds of car and light duty 

20 truck and medium and heavy duty truck standards 

21 achieved the largest greenhouse gas reductions ever

22 undertaken in the U.S. and one of the largest globally. 
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1 We thank EPA and NHTSA for their work to date. I look 

2 forward to working with the agencies and all our 

3 partners to ensure that we keep on combatting climate 

4 change by building great trucks. Thank you. 

5 MR. GRUNDLER: Thank you. Mr. Johnson, welcome. 

6 MR. JOHNSON: Hello. My name is Chris Johnson, 

7 and I am a former teacher and freelance writer. I live 

8 in Evanston, Illinois. I write about nature and the 

9 environment. I've written two books about forests, and 

10 I've written numerous articles about the environment in 

11 the Chicago area. During the summer of 2012, I did a 

12 lot of bike riding, and I noticed that I was constantly 

13 wheezing and coughing. I went to my doctor who ordered 

14 pulmonary function tests, and it turned out that my

15 childhood asthma had returned. 

16 Now, I am far from alone in the Chicago area in 

17 suffering from asthma. As the quality of our city's 

18 air has grown progressively worse, in 2014 the American 

19 Lung Association gave Chicago an "F" for its air 

20 quality. A major part of the problem with Chicago's 

21 air quality is the enormous amount of heavy truck 

22 traffic. As Mr. Brubaker pointed out earlier, the 
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1 number of trucks that come through Chicago. That is 

2 just no secret at all. We're a transportation center. 

3 And this affects not only people who live near or 

4 expressways, but also near major arteries. I live near 

5 a street, Dempster Street, that has heavy truck traffic 

6 going to and for -- between 294 and Evanston. And so, 

7 you really notice how heavy the truck traffic is. 

8 Heavy trucks are major contributors to air 

9 pollution. They account for about 10 percent of the 

10 miles driven in the United States, yet they produce 20 

11 percent of the transportation related carbon emissions. 

12 They also account for 20 percent of the oil used by 

13 the U.S. Transportation sector. For these health and 

14 economic reasons, I applaud the EPA and DOT for 

15 proposing to reduce trucks' fuel use and lower their 

16 carbon emissions. However, like other members of the 

17 Sierra Club, I urge you to reduce new fuel consumption 

18 even more by 40 percent by 2025 compared to 2020 

19 levels. 

20 In 2009, the Department of Energy reported that 

21 the heavy truck energy has or is developing the 

22 technology to meet higher mileage standards by 
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1 improving engines, transmissions, and tires and by 

2 using more aerodynamic designs. Higher mileage 

3 standards for heavy trucks would have enormous benefits 

4 for everyone concerned. We would save 200,000 barrels 

5 of oil a day and avoid putting an additional 40 million 

6 metric tons of global warming emissions into the 

7 atmosphere. This would be the equivalent of shutting 

8 down 12 coal-powered plants. 

9 By 2025, the average big rig driver would save

10 $30,000 a year in fuel costs. Manufacturers would save 

11 on shipping costs. Perhaps most importantly, the 

12 United States would realize approximately $37 billion 

13 in health and welfare benefits. Thank you very much. 

14 MR. GRUNDLER: Thank you very much. Mr. Mammen, 

15 welcome. 

16 MR. MAMMEN: Good afternoon. I'm Bill Mammen,

17 director of system and controls from Odyne Systems,

18 LLC, a manufacturer of hybrid systems for medium and 

19 heavy duty trucks. 

20 Our PHV technology has been deployed across the 

21 country, including right here in Chicago, in various 

22 vocational truck applications, demonstrating real world 
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1 fuel and emissions savings today. Odyne applauds the 

2 efforts of the EPA and NHTSA to work with the industry 

3 in ensuring the most fuel efficient technologies are 

4 developed and deployed to increase fuel efficiency and 

5 reduce greenhouse gases in the medium and heavy duty 

6 truck sector. Thank you for the opportunity to speak 

7 before you here today on the proposed Phase 2 rules. 

8 While scenario three, which represents the full 

9 compliance by 2027 for all truck classes and represent 

10 a positive guidepost for the industry, Odyne believes 

11 that cost-effective technology exists to meet timelines 

12 and technology adoption scenarios laid out in scenarios 

13 four and five, including fleet adoption rates of plug14 in hybrid technology, a technology Odyne Systems has 

15 developed and deployed in partnership with DoE and 

16 private fleets above and beyond the 10 percent market 

17 penetration rate of 2027, and at efficiency 

18 improvements far beyond the current projections for

19 various applications of vocational vehicles. 

20 In real world applications for vocational vehicles 

21 deployed with the Odyne hybrid technology, we have seen 

22 fuel efficiency improvements of 46 percent in driving 
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1 alone, and 64 percent in fuel savings when accounting 

2 for the average full workday, including driving, 

3 idling, and powering PTO takeoff activities. Based on 

4 testing paid for the U.S. Department of Energy and the 

5 State of California, Odyne Technology currently 

6 delivers 64 percent less CO2 and 95 percent less NOx 

7 emissions based on the full workday than non-hybrid

8 medium and heavy duty trucks meeting current standards. 

9 Odyne believes that improvements in drivetrain

10 hybrid control system optimization, both from 

11 technology advancements and increased data 

12 incorporation of workday assumptions and duty cycle

13 optimization, along with the continuing decreasing 

14 costs of components, and continuing volatility in 

15 fossil fuels, prices will drive the value proposition 

16 for hybrid development in the coming years. 

17 Odyne believes hybrids will play a larger role in 

18 fleet procurement in the next decade at efficiency 

19 rates higher than is currently modeled in scenario 

20 three assumptions. At a minimum, we would recommend 

21 that EPA increase the full compliance fuel efficiency 

22 increases for the vocational sector beyond the 16 to 20 
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1 percent or higher. And Odyne would welcome working

2 with the EPA on establishing specific assumptions and 

3 targets based on its data from the trucks on the road 

4 today with technologies currently under development. 

5 Odyne understands that it's difficult to model

6 fuel efficiency improvements for hybrid technologies 

7 within the GEM as hybrid systems interact with the 

8 transmission and the engine, the overall drivetrain in 

9 addition to auxiliary activities beyond driving not

10 currently well modeled in the GEM. But Odyne strongly 

11 believes that it's important to model the full day 

12 vocational vehicle duty cycle, including the driving 

13 and the idling and stationary operation of the truck 

14 mounted equipment through the power takeoff. Modeling 

15 the entire duty cycle would be consistent with efforts 

16 of CARB to understand the total emissions produced by 

17 vehicles throughout the entire work day. 

18 By not basing the proposed standards for 

19 vocational vehicles on the use of the hybrid PTO mode, 

20 the EPA could miss out on a significant opportunity to 

21 increase full workday fuel efficiency for vocational 

22 vehicles. The segment of vocational class market using 
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1 power takeoffs is significant. Odyne estimates there 

2 are an approximately 100,000 power takeoffs sold 

3 annually for medium and heavy duty trucks, and over a 

4 million on the road. In addition to accounting for the 

5 efficiency improvements from hybrid technology, it is 

6 not as clear as it could be in the proposed GEM model. 

7 Odyne would welcome the opportunity to work with the 

8 EPA on best practices and potential paths for modeling 

9 fuel efficiency increases from various applications of 

10 hybrid PTO mode in addition to hybrid propulsion. 

11 Should the EPA in its final rule decide not to

12 base its standard for vocational big trucks on the use 

13 of hybrid or EPTO, Odyne strongly encourages the EPA to 

14 develop and establish clear inbounding conditions for 

15 technologies to become eligible for off cycle credits. 

16 In Phase 1, the process was unclear for technologies 

17 to become eligible for these credits, which we believe 

18 was a major hindrance for the industry to drive these 

19 types of innovations. Odyne and other aligned 

20 stakeholders, like EDTA and CalStart, would also 

21 welcome the opportunity to work with the EPA and 

22 develop these conditions and clear timelines for 
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1 earning off cycle credits for the development of hybrid 

2 PTO technologies. 

3 Overall, Odyne would, again, like to thank the EPA 

4 and NHTSA for its developing these proposed regulations 

5 in Phase 2. We look forward to working with the EPA 

6 and NHTSA team going forward as the rules become final 

7 over the next year. Thank you. 

8 MR. GRUNDLER: Thank you so much. Mr. Barton?

9 MR. BARTON: Good afternoon, and thank you for

10 listening today. It's an honor to be a part of this 

11 panel. 

12 MR. GRUNDLER: Thank you. 

13 MR. BARTON: I own a company called Green 

14 Transportation Solutions that was born in Cook County. 

15 Still live in Cook County, and I'm a member of the

16 Sierra Club. And my company is committed to the use of 

17 the environmentally safe and fuel efficient 

18 transportation options for corporate and government

19 fleets. And, in fact, we partnered with the Main 

20 Township Highway Department in Illinois to create a

21 green fleet manual, which I've brought a sample of 

22 today, which basically outlines the fleets anywhere, 
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1 but particularly in Illinois, on the steps that they 

2 can take to green their fleet. 

3 We made this available for free, for every 

4 township in Illinois. And it's essentially a case 

5 study with, you know, green fleet tips and techniques 

6 going down to no idling and route management as well as 

7 how to navigate through some of the Federal and state 

8 grants that are currently available. We also have this 

9 manual available for free download at our website, 

10 greentransportationsolutions.com. 

11 So beyond the costly vehicle upgrades and 

12 modifications that are being discussed here today, it 

13 is rather difficult for some of these drivers to 

14 purchase some of these things. We usually actually

15 recommend three simple and inexpensive ways to reduce 

16 petroleum consumption, and, thus, greenhouse gas 

17 emissions with our clients. I'll tell you about those 

18 now, and I'll stick to my timeframe as well. 

19 The first is to increase the use and availability 

20 of biodiesel fuels in trucks. Most trucks only use a 

21 blend of five percent when they're capable of using

22 upwards towards 20 percent. So that comes down to the 
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1 availability and their choice at the pump. Often 

2 enough they don't have that choice, and if they did

3 more often they would choose it. 

4 As most people know, increasing biodiesel blends 

5 will automatically reduce petroleum consumption because 

6 you're using five percent, 10 percent, or 20 percent 

7 less petroleum, and also providing rural economic 

8 benefits domestically, plus a significant reduction in 

9 greenhouse gases by -- at the molecular structure 

10 having an oxygen piece component to that. 

11 So the second is to promote and enforce an idle 

12 reduction policy. That's rather simple. It's been

13 discussed here today. It does get zero miles per 

14 gallon, such as the hybrid vehicles. They're somewhat 

15 more expensive, and they do have payback, but you can 

16 reduce your idle time without a hybrid through 

17 management. So that would just come down to enforcing 

18 really because there is an idling law in Illinois 

19 already, and if you walk around the city it's not 

20 necessarily followed all the time or enforced for a

21 variety of reasons. So if there could be stronger 

22 enforcement near communities, particularly schools and 
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1 parks, as the parts per million for particulate matter 

2 go way up for young children with smaller lungs. 

3 The third is to incorporate a tire pressure 

4 screening system that was also discussed by the 

5 previous panel. It's very important for not only fuel 

6 efficiency, but for safety. It is one of the simplest 

7 ways to increase your fuel economy. It does take 

8 management. It does take participation by the drivers. 

9 And also many, many safety improvements having 

10 properly inflated tires. 

11 In conclusion, I would like to thank the 

12 Administration. You're doing a wonderful job. I 

13 support you, and I know it's a challenging position to 

14 be in to try to please everybody. Not easy. And I’d 

15 respectfully urge you to make the standards stronger if 

16 possible, and further reduce fuel usage up to 40 

17 percent by the year 2025. Thank you once again. 

18 MR. GRUNDLER: Thank you. Reverend Gallagher,

19 welcome back. Good to see you again. 

20 REVEREND GALLAGHER: Good afternoon. I'm the 

21 Reverend Doctor Terry Gallagher, and I appreciate the 

22 opportunity to speak with you today on the critical
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1 issue of heavy duty vehicle fuel economy and global

2 warming addition standards. I rise to speak today on 

3 behalf of communities of faith, but, most importantly, 

4 on behalf of my grandkids and their peers across the 

5 globe. 

6 Allow me to begin with the observation, if you

7 don't know me, that I'm a bit of an odd duck. By that 

8 I mean I accepted the call to ministry after I spent 32 

9 years in the chemical industry first as an engineer and 

10 ultimately as plant manager of a couple of different 

11 plants. So I'll be speaking from that educational 

12 experiential basis as well as from my ministry as a

13 public theologian whose focus is on ecological justice. 

14 Ecological justice is simply defined as every human 

15 being has an inalienable right to live in an 

16 environment that does not damage their health, 

17 irregardless of their zip code. 

18 My industrial career spanned decades during which 

19 most of the significant environmental regulations came 

20 into existence. I have to confess that during those 

21 times decades ago, as each regulation ruled out, we in 

22 industry would scream, and wail, and gnash our teeth 
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1 that you're driving us out of business, that the sole 

2 purpose of the EPA and the Federal standards was to

3 drive American business out of existence, you know,

4 kind of like what you hear these days so in response to 

5 these and other proposed standards that would reduce 

6 the amount of carbon pollution that we throw up in the 

7 air. 

8 But here's the burden of truth. We didn't go out 

9 of business. We actually got better at what we were 

10 doing. We got better at what we were supposed to be 

11 doing all along, which is manufacturing with excellence 

12 in response to the restrictions on what we could put 

13 into the air, dump into the waters, or bury 

14 underground. We had to get better at controlling our 

15 manufacturing processes and controlling our operations. 

16 As a result, our yields improved. Our quality 

17 improved. Our safety improved. Our streams improved. 

18 Some of the lesser manufacturers did run for 

19 foreign soils so to avoid regulations, but those who 

20 stayed got better at what they do. We still grumbled 

21 about you guys, but maybe with a touch less animosity 

22 than at first. I understand that you all face growing 
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1 criticisms for doing what you're intentionally purposed 

2 to do. I understand that daily you get threatened with 

3 budget cuts or get treated to the mindless criticism of 

4 a senator with a snowball saying that the snowball 

5 proves that climate change is a hoax, and so is your 

6 agency. I could understand that you feel under 

7 appreciated for your diligence in protecting the 

8 environment. I understand, but I don't care, and 

9 neither should you. You're doing your job. 

10 The protest and criticisms and baseless attacks 

11 from the greed-based special interest groups are part 

12 and parcel of what will happen when you're doing your 

13 job right. If you're not getting them, you got to 

14 question if you're going far enough. That's been true 

15 for your agency from day one, and it'll continue to be 

16 true as long as there are earth systems that need to be 

17 protected for the benefit of the present and the future 

18 generations. 

19 You know as well as I do that the current fossil 

20 fuel burning path our society is on is incompatible

21 with human civilization. There's no other way to say 

22 it. The path we're on is incompatible with human 
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1 civilization. The only question is time. If our kids 

2 and our grandkids are to have a future, then ultimately 

3 the majority of the fossil fuels have to stay exactly 

4 where they are right now, deep in the earth, not in the 

5 air we breathe. My good friends at the Union of 

6 Concerned Scientists have already pointed out that 

7 their studies show you can do what you intend to do

8 faster and at a deeper level. And I would encourage 

9 you strongly to pay attention to their recommendation. 

10 So while I applaud your efforts in developing the 

11 heavy duty vehicle fuel economy and global warming 

12 emission standards, I also want to tell you, which 

13 should be an obvious conclusion. These standards are 

14 simply a start on a very necessary path to a carbon

15 free future. In truth it's a baby step that's taken 

16 too long to come into being. After all, the Supreme 

17 Court gave you the authority to regulate carbon back in 

18 2007. So I would ask you to bring a greater sense of 

19 urgency to this very necessary work. I know greater 

20 urgency in your implementation plans will undoubtedly 

21 incur greater wrath and increased attacks and threats 

22 to cut your budget, but being comfortable is not your 
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1 job. Your mandate is to protect the earth and its life 

2 systems. And my kids, and my grandkids across the 

3 globe are counting on you to do your job. Thank you. 

4 MR. GRUNDLER: Thank you, sir. Mr. Walgenbach, 

5 care to follow that? 

6 (Laughter.) 

7 MR. WALGENBACH: I do as a matter of fact, and

8 great pronunciation, by the way. I am Kevin Walgenbach 

9 with the National Ready Mixed Concrete Association. 

10 Thank you for providing the opportunity to speak here 

11 today on Phase 2. 

12 NRMCA represents an industry with more 2,200 

13 companies and subsidiaries that employ more than 

14 125,000 American workers to manufacture and deliver

15 ready mixed concrete. The industry includes 70,000

16 ready mixed concrete trucks and 5,000 ready mixed 

17 concrete plants. 

18 The industry manufactures a construction material 

19 vital for constructing our built environment. From

20 roads and bridges to homes and highways, our built 

21 environment cannot be realized without the use of ready 

22 mixed concrete. In 2014 alone, the industry produced 
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1 more than 324 million cubic yards of concrete, the vast 

2 majority of which being delivered in place using ready 

3 mixed concrete trucks. 

4 NRMCA holds a number of poignant concerns with

5 Phase 2, including in part costs, technology reliance, 

6 and mainly truck weight challenges. I'm going to focus 

7 exclusively on truck weights today. The other issues 

8 and analysis and argument will come in our written 

9 comments. 

10 Currently the vast majority of American ready 

11 mixed concrete markets employ single unit concrete 

12 mixer trucks operating on between two to seven axles to 

13 deliver ready mixed concrete to its point of placement. 

14 Under the proposal, these trucks would fit in the 

15 definition of vocational heavy duty Class A trucks as 

16 characterized in the proposal. For the purposes of the 

17 proposal and today, that's the set of trucks I'll focus 

18 on. 

19 In the proposal, EPA and NHTSA suggest weight 

20 reduction as a viable method to meet the proposal's

21 requirements. This approach is infeasible as applied 

22 to ready mixed concrete trucks. Due to the reality of 
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1 the necessary configuration of trucks, hauling ready 

2 mixed concrete, combined with current regulations from 

3 numerous other U.S. regulatory bodies, poses a very

4 unique and continuing challenge to the industry. 

5 The necessity for manufacturing a concrete mixer 

6 truck with the lowest possible weight has existed as a 

7 market force since the inception of truck weight 

8 regulations. Manufacturing a lightweight mixer truck 

9 that meets all regulatory compliance threshold and that 

10 still can haul a full payload remains a constant 

11 challenge reliant on innovation and creativity. 

12 The proposal makes assumptions about heavy duty 

13 truck weights in order to make suggestions about how 

14 weight reduction can be applied to meeting the 

15 proposal's requirements. These assumptions in the case 

16 of mixer trucks are incorrect and miss the reality of a 

17 mixer truck's true tare and payload weights due to 

18 structural design and specialized equipment installed 

19 on mixer trucks for hauling a heavy product such as

20 ready mixed concrete. Under Federal weight limits,

21 there is little extra room for carrying payload. 

22 In addition to the Federal weight tolerances, 
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1 structural designs, and necessary specialized industry 

2 equipment along with previous emission regulation 

3 requirements that have added weight to mixer trucks, 

4 the overall allowable weight of mixer trucks has 

5 reached its limits, not to mention the current weight 

6 of mixer trucks includes the weight changes needed to 

7 comply with Phase 1 and alternative material 

8 suggestions mentioned in this Phase 2 proposal. 

9 All of these weight considerations have pushed

10 ready mixed concrete producers to running mixer trucks 

11 in many cases with a .002 percent margin of weight 

12 threshold, meaning under such weight conditions a truck 

13 merely getting dirty may put it over the legal weight 

14 limits and risk noncompliance. Furthermore, the nature 

15 of hauling and delivering concrete gives way to various 

16 driving road, weather, and construction site 

17 conditions. As well, the differences between urban and 

18 rural environments dictate specialized trucks that can 

19 be shorter or longer, which drastically impact weight 

20 considerations. 

21 Due to such realities, mixer trucks are designed 

22 to meet this inevitable rough environment. Such a 
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1 design requires materials that can handle these 

2 stresses and keep trucks moving. These materials 

3 invariably add weight to a mixer truck's design. 

4 Many of the methods EPA and NHTSA suggest in Phase 

5 1 and Phase 2 for complying with the proposal are 

6 already being implemented by the industry, and numerous 

7 other suggestions in Phase 2 are simply not practical 

8 for mixer trucks, such as idling reduction technology, 

9 which if used in a concrete truck risks the concrete 

10 hardening inside the drum potentially causing thousands 

11 of dollars of repairs or a new drum and/or voided 

12 concretes. These realities leave technology that has 

13 yet to be invented or perfected as the method the 

14 industry is most likely left with at a disposal for

15 complying with Phase 2. 

16 The consequence of adding more weight to mixer

17 trucks for Phase 2 compliance results in achieving the 

18 opposite goal intended for Phase 2. Simply put, if the 

19 industry is forced to reduce its payload in order to 

20 meet low weight tolerances, the industry will then be 

21 forced to be -- to use more trucks making more trips to 

22 deliver the same amount of concrete. More trips more 
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1 means increased emissions, increased fuel consumption, 

2 more trucks sitting in traffic, and longer hours for 

3 industry drivers. 

4 The ready mixed concrete industry is asking for 

5 the opportunity to be compliant with Phase 2 and still 

6 be productive. To this end, NRMCA recommends that EPA 

7 and NHTSA instead of pushing weight reductions for 

8 ready mixed trucks advocate for increased weight 

9 tolerances in amounts large enough to offset the 

10 weights of new equipment and technology that will be 

11 employed for compliance with Phase 2. 

12 Thank you again for the opportunity to speak 

13 today. I’d be happy to answer any questions. 

14 MR. GRUNDLER: Thank you, sir. I just have one 

15 comment to Mr. Mammen. If you'd be willing to share 

16 whatever information you have, test information you

17 have, with respect to the hybrid systems that you are 

18 working on, that would be very useful to us. 

19 MR. MAMMEN: Yes. The system that we do is a PTO20 based hybrid system, so it attaches and can handle some 

21 of the concerns that have been brought up today, 

22 because what we do is we do -- are capable of running 
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1 things at the job site, which is what we focus on. So 

2 not only is our hybrid system connected to the 

3 powertrain and provides propulsion hybrid, like 

4 vehicles on the road today that are hybrids. When we 

5 get to the job site, we can shut down the diesel engine 

6 and we can run all of the equipment that's needed to be 

7 run off of the hybrid system. And we can run all of 

8 the extra loads. Sometimes they haul generators. 

9 Sometimes they haul additional engines to do additional 

10 work. Our hybrid system can offset all of that and run 

11 it all off electric. 

12 MR. GRUNDLER: Great. So if you could just 

13 provide in your written, you know, more detailed 

14 information about your product, its effectiveness, your 

15 views of the market penetration. That's the kind of 

16 information we need to help look at the stringency.

17 MR. MAMMEN: Yes, we can do that, and we can also 

18 bring in some -- as I mentioned, we had some large 

19 programs with the Department of Energy, and South 

20 Coast, and CEC, and a lot of fleet data we collected 

21 over the years. 

22 MR. GRUNDLER: Great. 
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1 MR. MAMMEN: So we can bring that to the table and 

2 show you some -- what it can do. 

3 MR. GRUNDLER: Perfect. 

4 MR. TAMM: And just to add one other parameter

5 we'd be interested in is if there's information on cost 

6 and the type of duty the equipment would do. 

7 MR. MAMMEN: Absolutely. 

8 MR. GRUNDLER: Thank you so much, panel. Nope, 

9 stay there. 

10 MS. MARCHESSEAULT: For Mr. Mammen, you mentioned 

11 that Odyne systems would be interested in more clear 

12 conditions to be eligible for off cycle credits. Are 

13 there specific recommendations that you have that would 

14 make the program easier for Odyne systems? 

15 MR. MAMMEN: Yeah. I'm not prepared to talk about 

16 that right now. 

17 MS. MARCHESSEAULT: Sure. 

18 MR. MAMMEN: We were going to address that in our 

19 written comments, but what we're seeing is a way to, 

20 you know, to incentivize our technology: how do we get 

21 into the system as a non-OEM or as an intermediate 

22 stage type manufacturer of a product. 
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1 MR. GRUNDLER: Excellent. Thank you again for

2 your time and efforts. Panel nine, come on down. 

3 Again, if there's anyone in the audience that has not 

4 registered and wishes to speak, please tell our team 

5 outside. 

6 MR. TAMM: Ms. Walter, when you're ready, you may 

7 proceed. 

8 MS. WALTER: Hello. I'm not accustomed to 

9 speaking. Hello. My name is Pat Walter. I am a 

10 resident of Glenview, Illinois, which is a northern

11 suburb of Chicago. Thank you very much for holding

12 this hearing on the proposed efficiency standards for 

13 medium and heavy duty trucks. Earlier a gentleman said 

14 I've never driven a truck, but I am very fond of truck 

15 drivers. I think they do a lot of good work and are 

16 very responsible people. I also find it very 

17 reassuring to hear all of the questions and specific 

18 suggestions that the other company owners have provided 

19 in the hearing today. 

20 As stated, as part of your name, your agency is a 

21 vital part of our world with our very complicated 

22 environment. I am here for myself and others like me 
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1 who need these improved regulations and standards. I 

2 am a breast cancer survivor. I was last diagnosed in 

3 2007, the same year that the U.S. Supreme Court said 

4 that the carbon standards are an important part of our 

5 welfare. I wanted to put another face to the people 

6 who are very interested in improved air quality. 

7 I know how important that life is in our time on 

8 earth. I've tried to live with many eating habits -- 

9 as many healthy habits as I can. I don't smoke or 

10 drink. I've tried to take care of what I eat and 

11 everything. 

12 I have two sisters who don't live in the area. As 

13 an earlier testifier mentioned, Cook County is 

14 considered a grade F by the American Lung Association. 

15 I have a sister who lived in Albuquerque, which is a 

16 grade B. They have a lot fewer and less traffic. 

17 One current fact of breast cancer survivors is

18 that there are three million of us right now in the

19 United States per the National Cancer Institute. 

20 That's a very good thing. And we are the largest group 

21 of cancer survivors in the country. I'm sure that most 

22 people in the room either know someone or they are a 
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1 survivor themselves. 

2 On the other side, there's always going to be side 

3 effects from my successful treatments. Because my 

4 immune system is compromised, I am more sensitive to 

5 air and other environmental problems such as air 

6 pollution. So as medical science continues to improve, 

7 more people will survive breast and other types of 

8 cancer. I don't have asthma as other people mentioned, 

9 but I was present when my beloved niece had a serious 

10 asthma attack, and I have to say that's one of the most 

11 terrifying events I've had, including when I got my own 

12 diagnosis. I hope that the fuel efficiency standards 

13 will continue to be worked on, and I very much 

14 appreciate all your time and effort. 

15 In conclusion, I want to say that I can be careful 

16 about what I eat and drink, but since I don't live in a 

17 bubble, it's much more difficult to watch what type of 

18 air I breathe. Thank you. 

19 MR. TAMM: Okay. Thank you very much. Ms. 

20 Gutierrez. 

21 MS. GUTIERREZ: Hello. My name is Hannah 

22 Gutierrez, and I'm an intern with Environmental 
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1 Illinois. Environmental Illinois is a non-profit 

2 organization that is dedicated to protecting Illinois' 

3 natural resources and landscape. 

4 Thank you for the opportunity to testify today in 

5 support of the heavy duty vehicle emission standard. I 

6 applaud the Obama Administration and the EPA for 

7 proposing standards that will make our freight trucks 

8 cleaner and more efficient for the subsequent years. 

9 If finalized as proposed, the standards would cut one 

10 billion metric tons of global warming emissions over 

11 the lifetime of the trucks affected by the rule. That 

12 is roughly equivalent to the emissions created by 

13 powering all U.S. households for a year. 

14 Furthermore, the proposed rule would reduce toxic 

15 air pollution from idling trucks and refineries that 

16 produce fuel resulting in $37 billion in health and

17 welfare benefits, including reductions in mortality and 

18 hospitalizations. 

19 While the proposed standards are a good first 

20 step, I urge you to strengthen these standards to 

21 ensure the greatest reduction in oil use and global

22 warming emissions. Specifically, I encourage you to 
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1 finalize standards that reduce trucks' fuel use by 40 

2 percent by 2025. 

3 This issue is important to me as a Chicagoan 

4 native and a student at the University of Illinois at 

5 Urbana-Champaign. Up until the age of nine, I attended 

6 Chicago public schools. My playground was surrounded 

7 by skyscrapers and numerous vehicles passing by, 

8 vehicles whose emissions polluted the air and covered 

9 the city in a fog. When my family moved to the western 

10 suburbs of Chicago, my playground became an open grass 

11 field with fresh air to breathe. 

12 My family moved to the suburbs in part because of 

13 the health benefits. This should not be the case. All 

14 children should experience a childhood where they're 

15 exposed to a clean environment where going to play on 

16 the playground does not mean they have to inhale 

17 harmful toxins. 

18 The proposed rules are important to me not only 

19 because they will improve public health, but also 

20 because they will significantly cut carbon pollution. 

21 The impacts of climate change disproportionately harm 

22 poor communities and communities of color. This rule 
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1 is an important part of the President's Climate Action 

2 Plan, which will help to mitigate climate change 

3 impacts around the world. 

4 Once again, I applaud the Administration for 

5 proposing standards to make our trucks more efficient, 

6 and I urge you to finalize strong standards that reduce 

7 trucks' fuel use by 40 percent by 2025. Thank you for 

8 the opportunity to testify. 

9 MR. TAMM: And thank you very much for your 

10 comments. Ms. Houston? 

11 MS. HOUSTON: Hello, EPA Hearing Committee. My 

12 name is Korbin Houston, and I'm an intern with Illinois 

13 PIRG, or Illinois Public Interest Research Group. 

14 Thank you for the opportunity to testify today in 

15 support of strong emission standards for heavy duty

16 vehicles. 

17 Strong emission standards for heavy duty vehicles 

18 will save consumers money. According to the National 

19 Resource Defense Council and their partner 

20 organizations that have researched these standards,

21 consumers will save more money by the decrease of the 

22 use of oil and the use of efficiency technology. 
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1 Further, consumers support decreasing emissions. 

2 A Consumer Federation of America poll released in May 

3 2015 found that a majority of Americans favor requiring 

4 manufacturers to increase the fuel efficiency of heavy 

5 duty trucks while less than one-quarter opposed this 

6 requirement. Consumers' voices should be considered 

7 with these standards. The standards are also important 

8 for public health. The reduction of toxic air 

9 pollution by the proposal rule will result in $37 

10 billion in health and welfare benefits, including 

11 reductions in mortality and hospitalizations. 

12 Finally, these standards are important to me 

13 personally. I want these standards because I want to 

14 help in making America a greener and healthier place to 

15 live for myself and other citizens of this country. 

16 And it is beyond America. As global climate change

17 affects other citizens, the environment -- the health 

18 of people of this planet and the ecosystems that are 

19 going. In order -- having these emission standards, 

20 making them strong and effective emissions standards is 

21 one part of the many actions that must be taken in 

22 order to have a healthier planet to live on. 
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1 These standards are also important to me as being 

2 a millennial. Young people now and in the future will 

3 have to deal with the consequences of action or 

4 inaction when it does come to climate change. 

5 In conclusion, stronger emission standards for

6 heavy duty vehicles will save consumers money, improve 

7 public health, and help fight global climate change. 

8 Thank you for the opportunity to testify today. 

9 MR. TAMM: Thank you very much. Mr. McCabe? 

10 MR. MCCABE: Thank you, and thank you for the 

11 opportunity to provide testimony today regarding these 

12 standards. I'm here on behalf of Safety Clean Systems, 

13 Richardson, Texas, and a number of other companies 

14 engaged in the cradle-to-cradle recycling of used 

15 engine oil. These companies include Heritage Crystal 

16 Clean of Elgin, Illinois, Vertex Energy of Houston,

17 Texas, Vista Oil of Peachtree, Georgia, and Puralube 

18 USA of Wayne, Pennsylvania. Together we collect, 

19 process and refine used oil, and thereby turn the 

20 highly refined product made from crude oil into a 

21 renewable resource. 

22 We note that the proposed new Phase 2 standards 
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1 for fuel economy and greenhouse gas reductions for 

2 these vehicles look at a wide variety of options, and 

3 call for flexibility in how manufacturers meet the new 

4 standards using averaging, banking, and trading, or

5 ABT. We recommend allowing the manufacturers of 

6 relevant vehicles to obtain credit for significant 

7 greenhouse gas reduction benefits associated with re8 refining lubricating oil when this oil is supplied as 

9 an original factory fill. And further, we would like 

10 to explore with the agencies how ABT mechanisms can be 

11 used to allow credit for re-refined oil supplied during 

12 subsequent routine maintenance. 

13 Re-refining used lubricating oil generates 

14 significant environmental and energy benefits, and has 

15 been deemed by Federal agencies and national labs as an 

16 appropriate use for -- I'm sorry -- for conserving 

17 crude oil that is a non-renewable resource. 

18 Our independent life cycle analysis published in 

19 the American Chemistry Society Journal after peer 

20 review describes how the use of re-refined oil reduces 

21 greenhouse gas emissions compared to the use of engine 

22 oil made from virgin crude. This analysis, conducted 
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1 by Envira, a leading environmental consulting firm,

2 estimates that production of re-refined engine oil 

3 generates 70 percent fewer greenhouse gas emissions

4 than production of oil from virgin crude. For example, 

5 the total greenhouse gas savings from use of 50 million 

6 of refined oil is approximately 159,000 metric tons of 

7 CO2Eq. That's equal to avoiding emissions from the

8 combustion of 15 million gallons of number two fuel

9 oil. Simply put, every three gallons of re-refined

10 engine oil used avoid emissions equivalent to burning a 

11 gallon of diesel fuel. 

12 Our published analysis shows that even if we 

13 conservatively include other factors, such as emissions 

14 from collection of used oil, the use of re-refined oil 

15 represents 56 percent reduction in greenhouse gas 

16 emissions when compared to emissions from the 

17 production of lubricants made from the virgin crude. 

18 This is because refining engine oil from previously

19 refined used oil is a more efficient process than 

20 refining comparable engine oil from virgin crude. 

21 Significant carbon reductions are achievable 

22 through use of re-refined oil to lubricate engines as 
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1 original equipment and as part of maintenance of the 

2 vehicles. Allowing OEMs to receive credit for these 

3 greenhouse gas savings will provide them with 

4 additional flexibility to achieve the targets being set 

5 by the EPA and DOT. Further, allowing credits for 

6 initial fill and future maintenance will encourage more 

7 companies to use re-refined oil when studies show -- 

8 which studies show is preferable in terms of reducing 

9 greenhouse gas emissions. 

10 When the total life cycle benefits are factored 

11 in, the use of re-refined oil has benefits comparable 

12 to the use of low rolling resistance tires. With this 

13 type of tire, the standards are drafted to provide 

14 environmental benefits throughout the prescribed 

15 lifetime of the vehicle. The same standard could be 

16 adapted to avoid greenhouse gas emissions with re17 refined oil in original factor fill and service fill. 

18 Credit for future maintenance could be provided on 

19 a tradable basis allowing the manufacturer to buy GHG 

20 reduction benefits each time the oil is changed using 

21 re-refined oil in the future and maintenance cycles. 

22 By allowing future tradable credit, the manufacturer 
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1 would be given an incentive to promote the use of re2 refined oil in future oil changes through sales of re3 refined oil to their own network of maintenance 

4 facilities and dealers. 

5 We appreciate the opportunity to provide comments 

6 today, and we welcome any questions. Thank you. 

7 MR. TAMM: Thank you very much as well. Ms. 

8 Flynn? 

9 MS. FLYNN: Good afternoon. I hope you're doing 

10 well today. My name is Hannah Flynn. I am speaking on 

11 behalf of the Sierra Club and testifying as a resident 

12 of Hyde Park, Chicago. I'm a fourth year environmental 

13 studies major with a concentration in policy and 

14 economics at the University of Chicago. I believe 

15 strongly that ambitious, yet achievable, targets for 

16 fuel efficiency are a meaningful way to arrive at a

17 cleaner, healthier, and more economically robust set of 

18 regulations on heavy duty freight trucks. 

19 As a young person, I'm concerned about the future 

20 of this planet. It is well understood that the point 

21 of carbon -- at this point that carbon pollution, be it 

22 from methane or carbon dioxide, contributes greatly to 
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1 the warming of our atmosphere and the heightening of 

2 climate change. We're already seeing the effects of 

3 this. Just last week, Iran entered a heat dome, a 

4 high-pressure ridge that passed over the region 

5 exacerbating already sweltering temperatures to the

6 unbearable temperature of 165 degrees Fahrenheit. 

7 As President Obama said in announcing the Clean 

8 Power Plan, "We're the first generation to feel the

9 impacts of climate change, and the last generation that 

10 can do something about it." A whole spate of 

11 increasingly common climate events make it clear: dire 

12 words and a hefty responsibility to serve justice for 

13 future generations. But the bright side of this is

14 that we can make positive changes that will make 

15 impactful differences on our climate and ourselves. 

16 This all comes in a great period of ingenuity. 

17 I applaud the EPA for buckling down on fuel 

18 efficiency standards in the Phase 2 proposal. After 

19 all, some vehicles, such as tractor trailers, have 

20 meager fuel efficiency standards, fewer than 10 miles 

21 per gallon, that have not changed in decades. Of 

22 course, standards should be tailored to the vehicle
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1 type. 

2 Therefore, I urge the EPA to set an even higher 

3 target. It is entirely possible to have a 40 percent 

4 reduction in trucks' fuel usage by 2025. The 

5 technology exists in forms of drag treatment, advanced 

6 combustion, hybridization, and more. And the more 

7 there's a need for it, the more its market will be 

8 developed, infusing money into the market for fuel 

9 efficiency equipment. 

10 This policy will also benefit the truck drivers. 

11 By requiring less fuel to drive, the average big rig 

12 driver would save $30,000 annually. Customers will

13 benefit from reduced costs to ship goods. It's a 

14 winning economic situation. 

15 Where we can also win is on climate and having a 

16 stable planet. Reducing carbon pollution is an 

17 absolute requirement if we are to preserve it. The

18 warming potential of methane is extremely high, and the 

19 lasting power of carbon dioxide in our atmosphere is 

20 longer than my life span. I'm years away from even

21 thinking about having a family or even having an 

22 established career, but I know I want a biosphere that 
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1 is just as high quality as today, even if not even more 

2 so, an egalitarian planet with clean air and minimal 

3 extreme climate events. 

4 Thank you for listening. 

5 MR. TAMM: And thank you very much for your 

6 comments. Mr. Schaeffer? 

7 MR. SCHAEFFER: Thank you. Actually I commend the 

8 prior speaker. She took a little bit of my fire, but 

9 that's fine. Again, my name is Don Schaeffer. I'm

10 executive vice president of Midwest Truckers 

11 Association. And I want to thank U.S. EPA and DOT for 

12 providing this opportunity to comment on the Phase 2 

13 standards and how they're going to affect truck 

14 operations. 

15 Midwest Truckers Association represents more than 

16 3,400 companies in 18 states and Canada. These are

17 people and companies who operate trucks in their 

18 business operation. These are trucking companies, 

19 agriculture, construction, food service, private 

20 owners. They operate over the road. They operate 

21 locally. They're corporate. They're family operated. 

22 But they all come under the same rules and regulations 
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1 that are promulgated by the Federal government. 

2 You know, it's a rare opportunity and rare 

3 occasion that truck operators look favorably on a rule 

4 from the Federal government, and for the most part,

5 this is one of those instances. Truck operators 

6 really, and not to be disparaging, but have been at the 

7 mercy of the truck and trailer manufacturers for years 

8 to provide the equipment that is safe, but not always 

9 the most fuel efficient. Many of the efficiencies of 

10 commercial vehicles up to now have been up to the 

11 individual company. Well, we're the individual driver 

12 who has been trained to shift correctly and to be light 

13 on the gas pedal to achieve even minimal fuel savings. 

14 That's hard for a company to handle when their

15 best driver is lucky to get six or six and a half miles 

16 per gallon, and it's even worse for the local short

17 haul drivers. The gentleman who represented the Ready 

18 Mix Companies can tell you that very quickly. 

19 In the past, a burden has also been placed on the 

20 engine builders to improve emissions and eke out 

21 improved mileage. This rule is a cooperative effort to 

22 incorporate not just better engines, but to encourage 
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1 mechanical and aerodynamic improvements to commercial 

2 vehicles, be it a combination or a straight truck, 

3 delivery truck, light duty or heavy duty. Truck 

4 operators will be anxiously awaiting what changes lie 

5 ahead to reach the goal of a 40 percent reduction in 

6 fuel consumption in the next 10 years or so. 

7 The cost associated with achieving this goal and 

8 the pay off time may be a little bit debatable, but

9 even conservative figures that have been suggested 

10 point to a tangible return of extra dollars invested to 

11 improve fuel economy. Of course it depends on the 

12 number of miles traveled that will determine the 

13 payback level also, be it a local truck or be it an

14 over the road truck. 

15 For our average member, we expect a four-year 

16 payback based on the reality that regional and local 

17 drivers are not going to meet the same expectations as 

18 a fleet of over the road vehicles. And based on a 

19 typical depreciation schedule, the local and short haul 

20 trucks are going to be around longer, possibly meaning 

21 that an even bigger return on investment may be 

22 possible because they do keep that truck maybe up to 10 
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1 years. 

2 May we suggest, though, also that other measures 

3 should be considered in the big picture, especially

4 here in the Chicago area. There are other ways to make 

5 transportation more efficient for trucks, and thereby 

6 reduce congestion, unnecessary emissions due to idling 

7 and traffic jams, and what have you. Here in the 

8 Chicago area, we're working with transportation 

9 specialists at the University of Illinois-Chicago to 

10 encourage off peak delivery schedules for trucks. In 

11 these types of situations, trucks could run more 

12 efficiently and reduce traffic on the highways right 

13 now if we would encourage more nighttime and weekend 

14 deliveries. 

15 This would require the cooperation of shippers, 

16 trucker, and government bodies that would encourage off 

17 peak deliveries and maybe encourage a reduction in 

18 tolls on the tollway, maybe a change in the hours of 

19 service regulations to encourage truckers to operate at 

20 night. And also it would improve truck access. 

21 Midwest Truckers is also involved in projects right now 

22 with the Illinois Tollway to identify and to develop 
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1 more facilities for truck platooning and parking, to 

2 get the trucks closer to the delivery and pickoff 

3 points, and not be stuck in traffic jams or from some 

4 far away location. 

5 Finally, we look forward to the next step in this 

6 rulemaking process and have been encouraged to see a 

7 rule that can not only be an improvement for the 

8 environment, but also result in potential cost savings 

9 for these truck operators. And, of course, then that's 

10 passed onto the consumer, who could benefit from the 

11 fact that lower fuel consumption means less overhead 

12 costs. And if we can control transportation costs and 

13 delivery of goods and services and help save some 

14 money, I think everyone would agree that's a noble 

15 cause. 

16 Thank you. 

17 MR. TAMM: And thank you very much, too. Next, 

18 Mr. Rosenstein. 

19 MR. ROSENSTEIN: Good afternoon, ladies and 

20 gentlemen. My name is Dr. Bob Rosenstein. I'm a 

21 resident of the City of Chicago. Professionally I am a 

22 scientist with experience in industry, government, and 
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1 academe. My major reason for coming is that I do 

2 regard the global climate crisis as an existential 

3 issue for human civilization, and we have to do what we 

4 can to mitigate climate change. That means making vast 

5 improvements in transportation, and eventually phasing 

6 out completely fossil fuels and transforming to 

7 renewable energy. 

8 In that context, I think that I support strongly 

9 the Administration and the EPA for introducing these 

10 new standards for fuel efficiency. I think it also

11 will help the owners and the operators because the fuel 

12 costs will certainly be reduced, and we do hope that as 

13 we bring in renewable energy, that paradigm will 

14 continue. 

15 I just really wanted to focus in the time I have 

16 left on some personal observations. You know, when I 

17 was raising my son some years ago, we were in Des 

18 Plaines, and he saw this huge truck go by with all 

19 these emissions coming by. And he asked me how is that 

20 allowed, and I just said, well, probably the 

21 manufacturers make donations to some of the legislators 

22 in Springfield, and they, therefore, relax the 
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1 pollution controls. 

2 Because of the climate crisis, we can no longer 

3 afford such relaxations, but we also want to ensure

4 that our industries are profitable and sustainable. So 

5 I do think this paradigm with less consumption of fuel 

6 as we bring in renewable energy is something we should 

7 all support. 

8 One auxiliary point. I know there was a large

9 laundromat in -- it calls itself the -- in Cicero. And 

10 they have fuel costs of $5,000 -- heating costs of 

11 $5,000 a year. They introduced solar energy, and over 

12 a period of time it completely paid for their 

13 equipment, and they cut down their fuel -- $5,000 a

14 month fuel bill. So I think that these sort of savings 

15 would be realized as we bring in this fuel efficiency 

16 and we work in the scientific community concurrently to 

17 phase in renewable energy, you know, control release 

18 systems using hydrogen, which is a non-greenhouse gas. 

19 Those efforts are under way. But we have time to go, 

20 and these fuel efficient standards are going to help a 

21 lot. 

22 So just as a concerned citizen, I want to express 
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1 my appreciation to the Administration and the EPA for 

2 implementing these new standards. And as a citizen, 

3 which I'm mostly here today and also serving on the Air 

4 and Energy Committee of the Sierra Club, I just wanted 

5 to voice my support for these standards. We all have 

6 to move forward together. 

7 You know, if the planet is destroyed, our 

8 industries won't be able to operate either as well as 

9 people provide a safe habitat in which to raise 

10 families and grow. So I think we all have to support 

11 these and work together to achieve a green sustainable 

12 economy, and particularly in transportation. So thank 

13 you for the opportunity to testify, and I will do my 

14 best in the time I have left on this earth to work for 

15 a sustainable civilization so that the future 

16 generations will have a future. 

17 MR. TAMM: And thank you for your comments. Mr. 

18 McNicols. 

19 MR. MCNICOLS: Good afternoon. Ladies and 

20 gentlemen of the EPA and NHTSA, first of all, thank you 

21 for preparing and proposing this unified proposal for 

22 the greenhouse gas reductions and fuel reductions. 
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1 That spurs on the development of advanced technology to 

2 meet those requirements. 

3 The long-term plan stabilizes these crucial 

4 requirements and provides some much needed long-term 

5 regulatory certainty. As a developer and manufacturer 

6 of products for the medium and heavy duty commercial 

7 vehicles, it's noteworthy that it provides these 

8 aggressive targets and for improved performance, but it 

9 also is the phased in approach. 

10 Specifically, the sub-category for vocational 

11 vehicles and multiple route applications makes the 

12 regulations more clear and progress more easily 

13 identified. You've asked for some specific comments on 

14 proposed test duty cycles and their adequacy. We're 

15 reviewing those proposed cycles with our deployed 

16 vehicle data, and we'll provide the comments in our

17 written response. 

18 I applaud you for taking a high-level systems 

19 approach to measuring emissions and fuel economy. By 

20 considering the total vehicle design and application, 

21 the maximum impact can be obtained without the sub22 optimization of components' performance, such as 
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1 engines, transmissions, structures, and other things. 

2 This approach to standards drives a more integrated

3 approach to reducing greenhouse gas and fuel usage, and 

4 encourages the use of multiple, incremental 

5 technologies that result in greater overall 

6 improvements than individual systems can provide. 

7 However, regarding the vocational vehicles target 

8 improvements, the proposed requirement of 16 percent 

9 improvement may fall short of bringing about the 

10 necessary technologies to significantly impact this

11 sector. With roughly 30 percent of the greenhouse gas 

12 pollutants coming from the vocational vehicle and 

13 medium and heavy duty pickup truck sector, a greater 

14 percentage should be considered to drive the innovation 

15 even higher. 

16 As far as the ABT Program, it appears that the

17 credits for applying advanced technology for the 

18 manufacturers has disappeared. The way the current

19 proposal seems to be written still stops with the 

20 chassis OEMs, and does not allow for rollup of credits 

21 for applying energy saving technologies by delegated 

22 final stage manufacturers, such as vocational vehicle 
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1 manufacturers. 

2 We encourage you to take a broader view of how

3 final stage or delegated assembly manufacturers might 

4 add additional carbon reduction value that could flow 

5 back to the OEM. Without a return for the tedious work 

6 of bringing a new innovative product or technology to 

7 market, vehicle developers and manufacturers are not 

8 incentivized to take such risks. The cost of bringing 

9 a game changing technology or product to market faces 

10 many obstacles in breaking out of the status quo and 

11 the established market inertia. The lack of adequate 

12 incentives and credits for this taking this path makes 

13 it less desirable, potentially keeping new technologies 

14 from impacting our environment due to the lack of 

15 sufficient inducement or flexibility in accounting for 

16 these general credits. 

17 We are concerned that stringency levels alone may 

18 not drive the advanced technology, but there are also 

19 no credits to encourage them. Perhaps you will 

20 reconsider adding back in the credits for implementing 

21 advanced technology and find an equitable means of 

22 delegated final assembly OEMs to receive or roll up
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1 these credits. Your challenge will be to objectively 

2 new and innovative technologies and method applying

3 these advanced approaches that do not fit the status 

4 quo. 

5 Modifications to measurements and certification 

6 methods may be required, and flexibility to adapt these 

7 processes to accommodate promising and impactful 

8 technologies will be crucial. Some of these challenges 

9 include organizational empowerment, policy overhaul, 

10 working level encouragement and grace for risk taking, 

11 and flexible compliance throughout your organizations. 

12 We sincerely appreciate the overall body of work 

13 that's been poured into this unified proposal, and we 

14 appreciate that you are actively seeking stakeholder 

15 input and comment. We hope that in the end the result 

16 of this groundbreaking policy will have an impact for 

17 generations to come. 

18 Thank you for the time to hear our comments. We 

19 desire to stay connected and work with you as you shape 

20 the final rule structure. 

21 MR. TAMM: Okay. Thank you very much for your

22 comments. Are there any questions from the -- 
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1 MS. BRAKORA: I just have one comment on the Mr. 

2 Nichols -- McNicols. The innovative credits I believe 

3 are still available. They're just called off cycle

4 credits in this phase. 

5 MR. MCNICOLS: Okay. 

6 MS. BRAKORA: So they should -- you should still 

7 be able to -- a manufacturer still should be able to do 

8 some off cycle credit tests to obtain values for that. 

9 MR. MCNICOLS: And are they -- are they still 

10 focused on the OEM chassis builders, or does it go 

11 beyond chassis? 

12 MS. BRAKORA: In addition, there is the designated 

13 assembly or delegated assembly is still available. 

14 MR. MCNICOLS: Okay. 

15 MR. TAMM: Okay. So, again, want to thank the

16 panel. 

17 MR. GRUNDLER: I just want to particularly thank 

18 the students who have taken the time to come here. 

19 We've heard from the University of Illinois, the 

20 University of Chicago. I don't know what's wrong with 

21 your Northwestern colleagues, but hopefully before the 

22 end of the day -- 
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1 (Laughter.) 

2 FEMALE SPEAKER: She's not here. She's out of

3 town. 

4 MR. GRUNDLER: -- we'll have someone from 

5 Evanston. Thank you. 

6 MALE SPEAKER: (Off audio.) 

7 MR. GRUNDLER: Oh. 

8 (Laughter.) 

9 MR. GRUNDLER: Congratulations. Thank you very 

10 much. 

11 The next panel is panel nine made up of one 

12 person, Alexandra Sipiora. You're welcome to take the 

13 large table and tell us what you think. 

14 MS. SIPIORA: Good afternoon. My name is 

15 Alexandra Sipiora, and I'm testifying as a resident of 

16 Chicago. I'm in favor of the second phase of standards 

17 that both the Environmental Protection Agency and the 

18 Department of Public Transportation proposed to reduce 

19 carbon emissions and oil use from heavy freight trucks. 

20 The main reason I'm in favor of the proposed 

21 standards is that I have suffered from severe health 

22 problems that are exacerbated by pollution. Since I 
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1 suffer from multiple chemical sensitivities, I had to 

2 spend four years wearing charcoal masks whenever I left 

3 home. I was sensitive to the chemicals and exhaust, 

4 and I observed symptoms around large vehicles that have 

5 more than one axle. When the multiple chemical 

6 sensitivities were at their worst, I experienced 

7 symptoms even with layers of charcoal masks. During 

8 that time, I had to avoid Michigan Avenue and other

9 streets that have a lot of traffic from large vehicles. 

10 Since the charcoal masks made me unemployable, I could 

11 not work. 

12 Climate change has also affected my health and

13 that of people close to me. Since I take medicines

14 that can be dehydrating in hot weather, one summer I 

15 was treated in the emergency room four times for 

16 dehydration. The first time it happened I required

17 three bags of IV fluid. My grandmother once had to be 

18 hospitalized for a heat emergency, and after that she 

19 could never tolerate heat as well again. My parents 

20 and my best friend are all elderly, and I'm concerned 

21 about the effects the heat will have on their health. 

22 My best friend can't afford to run her air conditioner 
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1 except in the hottest of weather, so I'm especially

2 concerned about her. 

3 Finally, I have noticed that extreme heat in the 

4 last five years has caused more heat emergencies among 

5 the people here in downtown Chicago. I moved here in 

6 2007. Before 2011 I never had to call 9-1-1 for a heat 

7 emergency. I called for two in 2011 and at least one 

8 so far this year. They were severe emergencies because 

9 in two of these cases the victims were unconscious.

10 The proposed second phase of standards would 

11 address the climate change problem by reducing carbon 

12 emissions from 530 million metric tons to 270 million 

13 metric tons by 2030, and thus decrease global warming. 

14 In addition, both phases of standards would reduce oil 

15 consumption by 1.4 million barrels per day by 2030. 

16 Therefore, there would be less pollution. 

17 Once again, I'm strongly in favor of the proposed 

18 standards to reduce oil use and carbon emissions from 

19 heavy duty freight trucks. Thank you for your time. 

20 MR. GRUNDLER: Thank you, and thank you for 

21 sharing your story with us. Mr. Milburn, welcome. 

22 MR. MILBURN: Thank you. I just get to walk right 
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1 in and take care of business. I appreciate the 

2 opportunity to testify today. My name is Tim Milburn. 

3 I represent Greenways to Go, a consulting company in 

4 Illinois focusing on SmartWay to reduce pollution in 

5 transportation. I am here in strong support of the

6 proposed standards that will make our larger vehicles 

7 operate more cleanly and more efficiently for years to 

8 come. These proposed standards are a good step 

9 forward, and I urge you to adopt these standards as a 

10 minimum to ensure the significant reductions in oil

11 consumption, greenhouse gas, and other harmful 

12 emissions. 

13 I've spent much of my career in coal, oil, gas, 

14 and biofuel application as a combustion and pollution 

15 control engineer. I understand and physics of the 

16 resulting products of combustion and how they interact 

17 with the environment once they leave the tailpipe. 

18 Based on the broad consensus of many experts, I agree 

19 the time is now to act to reduce the CO2 emissions,

20 else we face increasingly serious challenges related to 

21 climate change. 

22 The transportation and energy sector represents 
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1 about one-third of the total CO2 generated in the U.S. 

2 Based on U.S. Energy Information Administration data, 

3 the targeted larger vehicle group represents about 20 

4 percent of the transportation total, second to light 

5 duty vehicles at 54 percent. 

6 A key role of democratic government is to create 

7 reachable, practical targets that benefit society and 

8 provide fair mechanisms to achieve these targets. If 

9 café standards for light duty vehicles have ben deemed 

10 necessary, this same logic should be equally applied 

11 for the larger vehicles as this vehicle group 

12 represents the highest per vehicle miles and lowest

13 fuel efficiencies, and, therefore, the highest sources 

14 of pollution per mile driven, and a large contributor 

15 to pollution and the associated negative human health 

16 and environmental impacts. The plan further targets 

17 having a two-year payback in fuel savings versus the 

18 incremental costs. This will be compelling to the 

19 fleet owners who should be money ahead after just a

20 couple of years. 

21 The proposed standards would establish a level

22 playing field to finding areas where American 
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1 innovation can provide solutions that benefit society 

2 as a whole by continuing to lead the U.S. and the world 

3 on a path of responsibly managing man's impacts on the 

4 earth's ecosystems while reducing the need for the U.S. 

5 to import oil. This leads to economic stimuli, jobs, 

6 reduced risks, and reduced costs required to globally 

7 protect oil, and reduce trade deficits in a more 

8 competitive U.S. global economic profile. 

9 These technical advances will soon come from 

10 somewhere in the world, and having the U.S. leading

11 these improvements will result in exporting of U.S.

12 technologies, meaning even more American jobs and cash 

13 flow. Initiatives like the fuel efficiency standards 

14 help educate all of us on why we should be mindful of 

15 proper stewardship of the finite air, water, and land 

16 resources we share. 

17 I urge you to finalize and adopt these or stronger 

18 standards. Simply put, this is the right thing to do. 

19 Thank you for the opportunity to testify. 

20 MR. GRUNDLER: Thank you. Any questions from the 

21 panel? 

22 (No response.) 
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1 MR. GRUNDLER: Thank you for your time. We're

2 going to take a break now. We are expecting a few more 

3 members of the Sierra Club to come and present 

4 testimony. I expect them around 4:40, which is when we 

5 will resume unless they show up earlier, and then we'll 

6 make an announcement. Thank you. 

7 (Break.) 

8 MR. GRUNDLER: We will now reconvene our public 

9 hearing on the EPA/NHTSA heavy duty fuel economy and 

10 greenhouse gas emissions standards. We believe this is 

11 our last panel of the day. Welcome, gentlemen. Mr. 

12 Riley, you may proceed when you are ready. 

13 MR. RILEY: Okay. Thank you. Well, thanks for 

14 the opportunity for me to testify. My name is Jeff

15 Riley. I'm the president of Riley Public Affairs. My 

16 firm often focuses on environmental and energy policy, 

17 including working on the passage of the new fuel 

18 economy standards for light trucks and cars in 2012. 

19 So I'm happy to be here again in support of these 

20 important new rules for large trucks. 

21 Like those other rules that the Obama 

22 Administration introduced, these, too, are overdue. 
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1 They also couldn't come at a more opportune time in

2 regards to addressing climate change, and in light of 

3 the finalized rules for the clean power plan that were 

4 recently announced. 

5 I support these new standards for trucks because 

6 it will benefit the economy, particularly the trucking 

7 industry, by spurring innovation in truck design so as 

8 to hedge against volatile oil prices, and it would 

9 result in truck drivers spending less money and time 

10 refueling. It'll improve our air quality and overall 

11 public health by reducing toxic air pollution from 

12 idling trucks and refineries, as well as avoiding 

13 upwards of one billion metric terms of carbon 

14 pollution. 

15 They have broad public support, as noted by the 

16 Consumer Federation of America, in a poll that found 

17 that 71 percent of consumers want manufacturers to 

18 increase fuel efficiency of heavy duty trucks. 

19 So once again, than you for the opportunity for me 

20 to testify, and I applaud the Administration, the EPA, 

21 the DOT, and all the other stakeholders involved who 

22 helped make these new standards a reality. 
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1 MR. GRUNDLER: Thank you very much. Mr. Green, 

2 proceed. 

3 MR. GREEN: Yes. Thank you for having me here 

4 today. Hi. My name is Jeff Green, and I live in 

5 Frankfurt, Illinois just south of Chicago. I have a 

6 bachelors in electrical engineering technology from

7 SIU. I've been a renewable energy advocate for 25 

8 years. I'm a founding member of IREA, which is 

9 Illinois Renewable Energy Association. We'll be 

10 putting our 14th Annual Renewable Energy Fair this 

11 August 22nd and 23rd in Oregon, Illinois. 

12 I've been passionate in my study of global warming 

13 for nine years now, and have come to the conclusion

14 that we are in for a world of hurt if we stay business 

15 as usual. Bold engineering in efficiency of trucking 

16 is a vital part of humanity staying sustainable on 

17 earth. 

18 In this discussion, I want to go to three 

19 different sources that I respect in their practicality 

20 and their deep commitment to sustainability on earth. 

21 Union of Concerned Scientists, Sierra Club, and Emory 

22 Levin's book, Reinventing Fire. I'm proud to be a 
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1 paying member of the first two groups, and I've enjoyed 

2 Reinventing Fire for its very thorough review of how to 

3 achieve a great economy on much less energy. These

4 groups are well studied and well informed on what is 

5 possible to keep our country great and leadership in a 

6 clean energy economy. 

7 Included in my handout, I will have a graph out of 

8 Reinventing Fire that shows six different areas of 

9 redesign of our Class A trucks and how we can achieve 

10 1.7 million barrels of diesel fuel per day savings by 

11 2050. At $2.47 a gallon -- 2012 prices I believe -- by 

12 year 2050, which translates to $67 billion per year, 

13 fuel prices in whatever form we have at that time will 

14 surely be higher than today. From my experience in

15 being in sustainability and a renewable energy advocate 

16 is that energy efficiency is a low hanging fruit with 

17 the least cost and greatest financial benefits. 

18 The trucking industry is no exception to this 

19 rule. Both sources -- Sierra Club and Union of 

20 Concerned Scientists -- show that combined trucking

21 standards of 2010 and 2015 could achieve a 40 percent 

22 reduction of fuel savings of new trucks by 2025. New 
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1 truck higher costs of $32,000 would save $30,000 in a 

2 year. That is a win in any business person's book.

3 We should be bold in our moves to be leaders in 

4 the world of engineering, product development, energy 

5 efficiency, and, therefore, business costs. This kind 

6 of move will benefit our climate, the health of our

7 children, and life on earth. This is the kind of win 

8 where -- that everyone will gain from. 

9 Thank you for your time. 

10 MR. GRUNDLER: Thank you. Any questions for this 

11 panel? 

12 (No response.) 

13 MR. GRUNDLER: Thank you for taking your time to 

14 tell us what you think. 

15 MR. GREEN: Okay. 

16 MS. MARCHESSEAULT: Thank you. 

17 MR. GRUNDLER: Anyone else in this room wish to 

18 provide testimony before we adjourn? 

19 (No response.) 

20 MR. GRUNDLER: Representative from Caterpillar? 

21 No? 

22 MALE SPEAKER: (Off audio.) 
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1 MR. GRUNDLER: This concludes our public hearing. 

2 Thank you very much. 

3 (Whereupon, at 4:56 p.m., the meeting was 

4 concluded.) 

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