Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 1 1 2 3 HEAVY-DUTY GREENHOUSE GAS AND FUEL EFFICIENCY 4 STANDARDS: PHASE 2 PROGRAM HEARING 5 6 7 Thursday, August 6, 2015 8 9:01 a.m. 9 10 11 12 13 14 15 16 17 18 19 20 Palmer House Hilton Hotel 21 17 East Monroe Street 22 Chicago, Illinois 60603Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 2 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 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 3 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 Offic e 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 Chicagoas 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 sp eak 13 today. To me, this is one of my highest 14 responsibilities, hearing directly from people on t he 15 impacts of decisions that their government may be 16 making. So this is an honor for me to be here, andI 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 secon d 20 phase of our joint program to regulate the greenhou se 21 gas emissions and fuel efficiency of heavy duty eng ines 22 and vehicles. This proposal, which we have issuedHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 4 1 under Clean Air Act and Energy Independence and 2 Security Act authorities, is an important part of t he 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 othe r 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 opportu nity 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 efficie nt 18 trucks. 19 The environmental and economic benefits of our 20 proposal are substantial. The standards as propose d 21 would cut greenhouse gas emissions by a billion met ric 22 tons, conserve up to 1.8 billion barrels of oil, an dHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 5 1 save vehicle owners fuel costs of about $170 billio n 2 over the lifetime of the vehicles sold. Payback 3 periods for truck owners would be favorable. The b uyer 4 of a new long haul truck in 2027 would recoup the e xtra 5 cost of the technology in under two years through f uel 6 savings. 7 EPA and NHTSA have worked to ensure that the 8 standards are harmonized between NHTSA and EPA. Th e 9 agencies have also worked very closely with the Sta te 10 of California's Air Resources Board in developing t hese 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 progr ams, 17 and would help to address the greenhouse gas reduct ion 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 u sHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 6 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 continu e to 4 meet the diverse need of our transportation sector 5 Today's hearing is being held to allow interes ted 6 parties to provide us with comments on this proposa l 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 comment s. 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 registrat ion 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 hearin g is 18 going to be conducted. Representing EPA with me onour 19 panel today is Jessica Brakora from our office. St eve 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 ofHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 7 1 the Fuel Economy Division at NHTSA. Gordon Trowbri dge 2 is the director of communications on the far end, a nd 3 next to him is Analiese Marchesseault from the Offi ce 4 of Chief Counsel of NHTSA. 5 This hearing will be conducted informally, and 6 formal rules of evidence will not apply. The presi ding 7 officers, however, are authorized to strike stateme nts 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 witn ess. 11 We will have helpful lights to remind you when you r 12 time will be up. 13 We're scheduled to run until about 5:00 or 6:0 0 14 p.m., but we will be here as long as it takes to al low 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 agendaat 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 ,Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 8 1 we'd be grateful if you signed the regulation sign up 2 list. 3 When all the witnesses on a panel have finishe d, 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 to day, 8 if any of you wishes to make any corrections to you r 9 remarks, please submit those corrections to EPA or 10 NHTSA within 30 days. If you'd like a transcript o f 11 today's proceedings, please make arrangements direc tly 12 with the court reporter sitting here in the middle 13 during one of the breaks. 14 I have one final announcement before turning i t 15 over to my NHTSA colleague. EPA would like to prov ide 16 additional notice regarding a proposed change to th e 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. Thi s 21 proposed change was included in the proposed regula tory 22 text, but not highlighted in the preamble to the Ph aseHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 9 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 ensur e 7 that commenters have adequate opportunity to commen t on 8 this issue, we are placing into the docket for this 9 rulemaking a memorandum providing additional detailon 10 this proposed change. Commenters interested in the 11 gasoline engine standards are encouraged to read th is 12 memorandum and provide comments on this change, alo ng 13 with any other comments on the proposed rule. 14 So at this time I’d like to turn it to over toJim 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 Traff ic 18 Safety Administration and the Department of 19 Transportation, I’d like to thank you for taking ti me 20 out of your busy schedule to come here and to provi de 21 comments on our proposed fuel efficiency and greenh ouse 22 gas emission regulations.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 10 1 NHTSA and the Department of Transportation wer e 2 proud to work with our partners at EPA to develop a 3 joint proposal for the second phase of the greenhou se 4 gas and fuel efficiency standards. Our goal is to 5 build on the successful Phase 1 standards for vehic le 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 truck s 9 and vans, and all types and sizes of buses and work 10 trucks. For the first time standards would apply t o 11 most heavy duty trailers. Trailer standards would 12 start in model year 2018. 13 The agencies are committed to the goal of sett ing 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 owne rs. 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 a nd 21 provides supporting information and the analysis 22 related to the proposal.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 11 1 In addition on June 19, NHTSA published a draf t 2 environmental impact statement for the proposed NHT SA 3 fuel efficiency regulations. The draft environment al 4 impact statement compares the environmental impacts of 5 the proposed fuel efficiency regulations with thoseof 6 a number of alternatives. In today's hearing, we 7 provide opportunity for the public to comment on bo th 8 the Notice of Proposed Rulemaking documents and NHT SA's 9 draft environmental impact statement. 10 Please note that while the comment period for 11 Notice of Proposed Rulemaking closes on September 1 7, 12 the comment period for the draft environmental impa ct 13 statement will close on August 31st. Our two Agenc ies 14 welcome feedback from stakeholders and the public t o 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 fro nt, 20 please state your name and affiliation, and to spea k 21 slowly and clearly so our court reporter can record 22 these proceedings accurately.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 12 1 And this time, I think we're ready to bring upthe 2 first panel. And as Chris noted, to assist in keep ing 3 the testimonies on track, we do have a series of 4 lights. Just for the speakers, you'll receive a gr een 5 light up until one minute. I'm sorry. There are f ive 6 minutes that we're targeting for each speaker. Forthe 7 first four minutes, the green light will be on. Th e 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 ma in 11 table, but we've also arranged for a staging area, 12 which are the chairs back there, and JoNell is wavi ng 13 back there. So we're going to call up the first pa nel, 14 and we would ask that panel to come up to the main 15 table, and then also call a second panel and ask th em 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 Hes s, 19 and Luke Tonachel. So if you all come to the -- th ank 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 ,Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 13 1 and David Cooke. I think we'll wait a moment until 2 everybody has a chance to be seated, and then we'llget 3 started. 4 Mr. Mandel, you may proceed. 5 MR. MANDEL: Thank you. Good morning. I'm Je d 6 Mandel. I'm president of the Truck and Engine 7 Manufacturers Association. EMA's members manufactu re 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 NHTS A's 12 historic Phase 1 rule. 13 That rule was a success for, among other reaso ns, 14 because the final rule was structured around certai n 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 marketplaceand 19 the complexity of product offerings, and avoiding 20 unintended consequences. 21 EMA and its members have advocated that simila r 22 principles guide the development and implementationofHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 14 1 Phase 2. Given EPA's and NHTSA's stated intent to 2 adopt a significantly more stringent program, one t hat 3 forces the development of technology, an appropriat e -- 4 the appropriate and necessary principles are somewh at 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 h as 10 advocated that EPA consider adopting a more aggress ive 11 timeline for the Phase 2 standards, along with lowe r 12 NOx if contemporaneous with the proposed Phase 2 13 standards. More important, California has indicate d 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 standar ds. 18 That alignment is a fundamental cornerstone to the 19 cost effectiveness and implementability of the worl d's 20 most stringent criteria emissions control program. 21 Full regulatory alignment was similarly critical tothe 22 success of Phase 1. Fifty-state harmonization like wiseHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 15 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 eno ugh 5 that California aligns itself with EPA's greenhousegas 6 limits, including on the same timeline recommended and 7 established by EPA. CARB also must continue to ful ly 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 ru le 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 ru le 21 must provide adequate lead time and stability, bala nce 22 stringency costs and implementation dates, look toHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 16 1 improve in opportunities beyond just those that arein 2 the control of truck and engine manufacturers, acco unt 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 -- progr am 10 of Phase 2 GHG reductions and fuel improvements. T he 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 commit ted 14 to work with all stakeholders to finalize a rule th at 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 propos al, 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 focusedonHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 17 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, whe n 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 conc ern, 9 but I'll take a moment to identify a few key concer ns. 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 attempt ing 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 improvement s in 21 freight efficiency. Yet based on our preliminary 22 assessments, even those super trucks, which includeHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 18 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 a dopt 6 rules that require the development of new technolog ies 7 beyond the super truck prototypes just now being 8 developed as the reference for compliance with Phas e 2. 9 Accordingly, we believe that it is necessary to fi nd 10 the reference assumptions and create many of the 11 underlying assumptions about technology penetration 12 rates for certain market segments in order to final ize 13 a technologically feasible and implementable rule. 14 EPA and the NHTSA also are proposing significa ntly 15 more robust and complex simulation models. With th ose 16 new models, significant test variability associated 17 with measurement accuracy, varying ambient conditio ns, 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. Wh ere 22 they cannot fully do so, it is incumbent on theHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 19 1 agencies to provide some degree of testing margin t o 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 certificatio n 8 levels contemplated by the proposed rule. 9 Consequently, the agencies' allowance of sufficient 10 test and audit margins are key to the implementatio n 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 ch ance 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 bala nce 20 of his time. 21 MR. MANDEL: Exactly. We know that EPA and NH TSA 22 are attempting to find a balance between separateHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 20 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 go t it 9 right. Among other things, in attempting to connec t 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 an d to 13 simulate that engine in GEM. The compliance marginis 14 absolutely necessary, especially in the context of an 15 agency audit to account for inherent variability an d 16 characterizing energy fuel consumption. Without th at 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 touchedon 22 today. We're providing our best technical assessme ntHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 21 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 h ave 4 worked to continuously improve it, even while makin g 5 incredible improvements in the reduction of criteri a 6 pollutants. We intend to continue to provide impro ved 7 fuel efficiency and the corresponding improvements in 8 GHG emissions. 9 To that end, it is essential that the final ru le 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 modelfor 18 the rest of rest of the testifiers today. 19 (Laughter.) 20 MR. GRUNDLER: Mr. Lutsey. 21 MR. LUTSEY: Fair enough. Good morning. Than k 22 you for the opportunity to provide remarks here on thisHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 22 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 tha t is 4 focused on providing technical information to suppo rt 5 governments in their decision-making and policies l ike 6 these Phase 2 regulations in leading vehicle market s 7 around the world. I'll make brief comments for ICC T 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 uptakeof 15 efficiency technology. Among the barriers are the 16 disconnect between who purchases the technology andwho 17 receives the fuel saving benefit in some cases, the 18 limited data available to truck owners on technolog ies' 19 real world benefits, and limited availability of th e 20 technologies themselves. 21 In our global work on vehicle efficiency, we h ave 22 found no evidence of any sustained fleet-wide incre aseHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 23 1 in any countries vehicle efficiency without efficie ncy 2 or CO2 regulations, even though efficiency technolo gy 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, transparenc y, 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, th e 18 rule is largely predicated upon well-understood, 19 highly-cost effective technologies. The technologi es 20 in the engine, transmission, aerodynamics, and tire 21 areas are exactly the ones that suppliers and vehic le 22 manufacturers have been discussing for the rule'sHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 24 1 timeframe. The trailer technologies embrace the 2 emerging technologies that have already been spurre d by 3 EPA's SmartWay Program and California's end use 4 regulation. Due to the agencies' decisions to relyon 5 primarily proven, available, cost-effective 6 technologies, the agencies can shift the standards 7 forward by three years from 2027 as proposed forwar d to 8 2024. This would allow sufficient lead time still for 9 manufacturers and truck buyers to gradually incorpo rate 10 the technologies into their operations over the nex t 11 nine years. 12 We have noticed several areas where the agenci es 13 do not fully incorporate available technologies. O ne 14 area is in the engines where Agencies -- the agenci es 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 t o 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 truckHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 25 1 technologies would mean the standards could go furt her 2 yet. 3 In addition, the proposed heavy duty pickup an d 4 van as well as the gasoline engine efficiency standards 5 appear to fall significant short in their promotionof 6 the full technology potential. Finally, this 7 rulemaking is key in establishing the U.S. as a glo bal 8 leader on freight truck efficiency. The government s of 9 Canada, China, Europe, India, Japan, Mexico, and ot hers 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 ou r 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'mKenHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 26 1 McAlinden, the advanced heavy duty regulation 2 supervisor for Ford Motor Company. It's a pleasureto 3 be here today to provide our perspective on this ve ry 4 important rulemaking. 5 We commend the efforts of the EPA and NHTSA inthe 6 difficult task of developing this second phase of t heir 7 greenhouse gas emissions and fuel efficiency standa rds 8 for medium and heavy duty engines and vehicles. 9 Moreover, we commend the agencies for working close ly 10 with the California Resources Board in developing t hese 11 proposed standards. We are committed to working wi th 12 EPA, NHTSA, and ARB to finalize these regulations a s a 13 single national program that would allow manufactur ers 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 aboutthe 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 call ed 22 Transit, which feature fuel efficient V-6 andHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 27 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 tru cks, 5 and motor homes. 6 Ford is investing billions of dollars over the 7 next five years to introduce technologies that impr ove 8 fuel economy and reduce the greenhouse gas emission s of 9 our fleet. We're driving innovation in every part of 10 our business to deliver advanced new products and t o 11 change the way the world moves. Commercial truck 12 customers demand technologies that provide value fo r 13 money while providing truck functionality, whether it's 14 volume for people or cargo, the ability to haul lar ge 15 loads, or to work off road. 16 Fuel economy continues to be very important toour 17 commercial truck customers, and Ford has invested i n 18 technologies to maintain customer satisfaction. Yo u 19 will continue to see us offer more great products w ith 20 advanced innovative technologies to improve the fue l 21 efficiency of our vehicles and to deliver outstandi ng 22 quality and features that our customers desire.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 28 1 Turning now to the proposed rule making, Ford 2 supports the continuation of the harmonized greenho use 3 gas emissions and fuel consumption regulatory frame work 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 propert ies 8 in that same time period. These external factors 9 increase the effective stringency in technology-for cing 10 aspects of the heavy duty greenhouse gas proposal 11 beyond what the numerical value of the standards al one 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 l ead 17 time to meet the requirements. As with Phase 1, th e 18 proposal includes a range of compliance mechanisms, 19 such as the ability to carry forward credits from p rior 20 model years as well as vocational vehicle and engin e 21 averaging banking and trading provisions. 22 Ford supports expansion of the Phase 1 allowan ceHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 29 1 to generate emission credits for CO2 improvements f or 2 technologies providing on road fuel consumption 3 benefits that are not captured by the emissions tes t 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 u se 7 of known technology found to be feasible and effect ive 8 in the market segment, preserve the utility and 9 functionality of these commercial vehicles, includi ng 10 maintaining separate gasoline and diesel targets, a re 11 compatible with the complexities of the marketplace , 12 and avoid unintended consequences. 13 Ford has some concerns with the accuracy of th e 14 greenhouse gas emissions model used to determine 15 compliance for vocational vehicles, particularly inthe 16 case of vehicles with heavy duty gasoline and light 17 heavy duty diesel engines. Ford recommends that da ta 18 is used to validate the model for these engines and 19 vehicles. Ford will provide detailed written comme nts 20 on this subject once we have fully evaluated the mo del. 21 We'll continue to cooperate with EPA and NHTSA 22 requests for data to support the refinement of the GEMHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 30 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 me dium 5 and heavy duty vehicles The EPA and NHTSA Phase 1 6 proposal was the first step to providing the clarit y, 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 expa nds 10 on this progress, setting challenging targets for 11 industry for the next decade. 12 Once again, Ford appreciates the opportunity t o 13 provide our testimony on this important rulemaking. We 14 are continuing to review all of the technical aspec ts 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 questi ons. 20 MR. GRUNDLER: Thank you. Mr. Mathers. 21 MR. MATHERS: Great, thank you. Jason Mathers , 22 Environmental Defense Fund. On behalf of theHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 31 1 Environmental Defense Fund and our more than one 2 million members nationwide, I sincerely thank you f or 3 the opportunity to testify today. 4 Freight trucks are one of the fastest-growing 5 sources of climate disrupting emissions. Leaders i n 6 business and the environmental community alike 7 recognize that rigorous, well-designed standards ca n 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 exist ing 11 technologies. In fact, in a recent Wall Street Jou rnal 12 op-ed, Fred Krupp, president of EDF, joined with In dra 13 Nooyi, chairman and CEO of Pepsico, in a call for 14 strong Federal standards to reduce fuel consumptionand 15 greenhouse gas emissions from heavy trucks. 16 Now, as proposed, the heavy truck fuel efficie ncy 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 emissionsHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 32 1 reductions and greater efficiency improvements. 2 Standards that are lacking currently current available 3 technology would be a terrible misread of the marke t 4 demand, and would fail to carry out the technology 5 spurring statutory requirements of the Nation's cle an 6 air laws. 7 We respectfully make the following recommendat ions 8 to realize the economic and environmental opportuni ties 9 of protective standards. Number one, strengthen th e 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 CO 2 14 emissions, ensuring that efficiency improvements donot 15 result in higher NOx and emissions. 16 Existing technologies have the potential to co st17 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, adva nced 20 technologies are demonstrating the ability to achie ve 21 even greater reductions. Engine improvements on th e 22 order of 15 percent will deliver cost savings for e ndHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 33 1 users. Analysis by Andrew Bally and Associates fou nd 2 that the final standard consistent with a 50 percen t 3 engine standard would reduce the total life cycle c ost 4 of owning a new super combination truck by 22 cents per 5 mile in 2030, saving fleet owners and their custome rs 6 tens of billions annually. 7 The second recommendation is to accelerate the 8 timing of the most stringent standards to 2024. Th e 9 compliance timeline in alternative four is consiste nt 10 with our assessment of the appropriate timeframe fo r 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 needto 15 reduce climate disrupting emissions. 16 The third recommendation is to ensure emission s 17 reductions regardless of fuel choice. Diesel is 18 currently the dominant fuel for heavy trucks. Whil e 19 it's likely to remain the most widely used fuel 20 throughout the Phase 2 proposal, gasoline and natur al 21 gas trucks are making inroads in different market 22 segments. The agencies need to safeguard projectedHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 34 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 abilit y of 4 natural gas trucks to deliver real world greenhousegas 5 reductions. Given the significant impact of upstre am 6 methane emissions, a recent ICCT study found that 7 "Inadequate attention to technologies designed to l imit 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 g as 13 engines have closed crank cases and the establishme nt 14 for the first time ever of whole time requirements for 15 L and G takes are important. While it's critical f or 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 vent ing 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.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 35 1 First, the Agency should use the current globa l 2 warming potential values put forward by the IPCC. 3 Second, the Agency should recognize the full impactof 4 methane by accounting for its impact in multiple ti me 5 periods. Third, the Agency should adopt the full f uel 6 cycle accounting approach for alternative fuels whi ch 7 the Agency chose to pursue in historic light duty 8 standards. 9 The agencies need to act on gasoline, too. Itis 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 betweenthe 13 diesel and gasoline standards over the Phase 2 prog ram 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 impor tant 21 as strong rules are to me professionally, it is 22 essential to me personally. Two months ago I wasHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 36 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 8 0 5 percent to avoid the worst impacts of a warming wor ld. 6 As much faith as I have in his ability and that ofhis 7 generation, it is irresponsible for us to burden hi m 8 with the immense challenges of a warming world. 9 While this effort is but one of the many neede d, 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. Congratulati ons 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 represen ting 19 our vehicle group this morning, and I appreciate th e 20 opportunity to give testimony regarding Phase 2 of 21 greenhouse gas emissions rules for commercial truck s. 22 Eaton is the power management company with 201 4Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 37 1 sales of $22.6 billion. We provide energy efficien t 2 solutions that help our customers effectively manag e 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, manufactur e, 8 and supply of drivetrain and powertrain systems and 9 critical components that reduce emissions and impro ve 10 fuel economy, stability, performance, and safety of 11 cars, light trucks, and commercial vehicles. 12 Products include transmissions, clutches, hybr id 13 power systems, superchargers, engine valves and val ve 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 appr oach 21 taken by both the U.S. EPA and NHTSA to reach out t o 22 stakeholders in the industry for in-depth technolog yHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 38 1 discussions early in the development of Phase 2. I t 2 cannot be said that the agencies did not listen to the 3 thoughts and concerns of commercial vehicle industr y 4 and other stakeholders who are part of the commerci al 5 vehicle value chain in the United States. 6 As we did in Phase 1, Eaton supports the appro ach 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 fo rces 12 to drive adoption of the most efficient commerciall y13 available technologies. 14 By following the structure created in the Phas e 1 15 for Phase 2, the agencies can rely on a proven conc ept 16 that will build upon established regulatory structu re, 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 andHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 39 1 vehicle standards found in Phase 1 should be mainta ined 2 in Phase 2. The separate standards reflect the rea lity 3 of the commercial vehicle market, drive adoption of 4 efficient technologies, and provide a structure tha t is 5 proven and accepted in the U.S. market today. Eato n 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. Th is 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 technolo gy 14 solutions to meet the prescribed standards with the 15 reliability, safety, and performance demanded by ou r 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. Th e 20 powertrain test accurately measures the fuel benefi ts 21 of advanced technologies in realistic driving 22 conditions. We believe that the powertrain test is aHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 40 1 critical component to model-based certification. T he 2 fact that the benefits of advanced transmissions an d 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 transmissi on 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 unteste d 11 technologies. We believe that powertrain test opti on 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 wha t 15 the new regulations can be, giving clear, achievabl e 16 objectives that spur innovation development while 17 avoiding a negative impact on the economy, and 18 promoting leadership in commercial vehicle efficien cy. 19 Eaton Believes that many of the technologies neede d 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 toHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 41 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 rulein 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, o r 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 medi um 17 and heavy duty truck proposal is the result of a 18 tremendous amount of work. NRDC thanks you and you r 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 communi tyHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 42 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 Administrati on 7 shows that medium and heavy trucks will be the fast

8 growing source of oil demand and carbon pollution i n 9 the transportation sector if new truck standards ar e 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 impor tant 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 anal ysisHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 43 1 showing that the new fleet fuel consumption and 2 greenhouse gas emissions can be reduced by at least40 3 percent from 2010 levels by 2025. Within the propo sal 4 alternative four, which achieves full compliance in 5 2024, is the closest to meeting our target. When i t 6 comes to cutting carbon and reducing our dangerous 7 dependence on oil, every year counts. 8 The agencies' own analysis shows that alternat ive 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 b y an 13 additional 13 percent, and increases net benefits b y 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 real ity, 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 speedsHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 44 1 results in better performance on the test without a ny 2 new technology addition. 3 NRDC supports the structure of a separate engi ne 4 standard because we think it's necessary to ensure that 5 all cost-effective engine efficiency technologies w ill 6 be applied to the engine. However, the proposed en gine 7 standard appears too modest to drive the full speedof 8 existing technology adoption, and certainly fails t o be 9 technology forcing. We urge the agencies to streng then 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 manufactu ring 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 appl ying 20 technologies that improve fuel efficiency in mediumand 21 heavy duty trucks. We believe that the standards c an 22 boost manufacturing jobs across the country. TodayHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 45 1 more than 36,000 engineers, technicians, and assemb ly 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 gasolin e 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 economyand 17 for the environment. We greatly appreciate the har d 18 work of the agencies on this comprehensive and thor ough 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 makeHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 46 1 improvements to the final rule. Thank you very muc h. 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 withMr. 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 h as a 12 decision to make in October about strengthening tha t 13 ozone standard, so we certainly heard from Californ ia 14 and others about their interest in further NOx 15 reductions. So I was intrigued by your statement t hat 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 memb ers 22 on future NOx reductions? We know it's not part ofHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 47 1 this rule. We want to be clear on that. But giventhe 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 expe ct 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 g et 9 it over it, I'm sure. 10 You know, we are -- we've had conversations wi th 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 brandnew 15 trucks as opposed to other sources of pollutants th at 16 contribute to the ozone problem. 17 Having said that, were also mindful of the ozo ne 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 t heir 22 resources board and EPA as to what they think theHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 48 1 possible course might be, including setting priorit ies. 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 ne ed 6 to hear as to whether one is a priority over the ot her 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 t o 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 potent ial 15 inventory that's affecting ozone compliance. 16 So there's -- it's a complicated issue. We wi ll 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 agenc ies, 22 but we want to make sure we understand what the pro blemHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 49 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 agen cies 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 t o 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 howto 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 bene fits 17 of these better trucks is our highest priority. 18 MR. MANDEL: And I'm glad you asked me about t hat 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 assure dHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 50 1 that they really want those, they want fuel efficie ncy 2 improvements. They want lower greenhouse gas 3 emissions. And they're incredibly sophisticated an d 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 be st 8 to get that fuel efficiency. We think the marketpl ace 9 has a significant role here. 10 We understand and have been a party to assisti ng 11 both EPA and NHTSA to make GEM more sophisticated t han 12 in Phase 1. We're also aware that the agencies wan t to 13 assure that when manufacturers make their GEM 14 calculations, that there's some verification of tha t 15 process. But what -- but what I was particularly 16 referring to in my testimony is that the verificati on 17 of that process with the proposed coast down test when 18 there are an enormous number of variabilities in ju st 19 right to assure, again, that GEM calculation, that' s 20 where we have to work to eliminate the variabilitie s to 21 an extent possible. 22 Many of them don't exist in Phase 1 because th e --Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 51 1 everybody tested on the same track, for example. S o if 2 there's testing on variable tracts, it adds 3 variability, and obviously there's more variabilityin 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 conditi ons 7 that our customers are actually using the trucks, a nd 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 b est 11 greenhouse gas reductions for their particular frei ght 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 inadvertentl y 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.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 52 1 MR. GRUNDLER: Fair enough. Thank you. I’d l ike 2 to introduce my esteemed counsel, Steve Silverman, who 3 just joined us. Welcome. Mr. Lutsey, I want to th ank 4 you for providing all of your sites to your remarks . 5 That's going to be very, very helpful. And you als o 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 intereste d in 12 receiving data to help us validate the proposed model. 13 We want to make sure we get that right. Continuin g 14 the theme, Mr. Mathers, will EDF be providing 15 information and data to support your assertion thata 16 15 percent increase in stringency is feasible? 17 MR. MATHERS: We will. 18 MR. GRUNDLER: Great. And one more question f or 19 Luke. You mentioned a jobs assessment you're worki ng 20 on with the Blue Green Alliance. 21 MR. HESS: That's right. 22 MR. GRUNDLER: Will that be published in time toHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 53 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. An y 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 i n 12 the staging area to come up to the main table, plea se. 13 And then I would invite the third panel to go to t he 14 staging area. Again, that's the chairs over on thefar 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, AmericanHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 54 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 reduci ng 9 emissions in oil consumption from the transportatio n 10 sector. The proposed phrase two standards, built o n 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 Efficien cy 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 sever al 21 ways. Number one, full vehicle integration. The 22 greenhouse gas emissions model in GEM is moreHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 55 1 sophisticated in Phase 2, which would allow many mo re 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 protocol s 6 will promote integration of engine, transmission, a nd 7 vehicle components. 8 ACEEE strongly supports the agencies' proposal 9 that tractor and vehicle manufacturers -- vocationa l 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 affordab le 17 trailer and tire technologies can deliver more than10- 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 cyc leHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 56 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 eng ine 8 points -- operating engine operating points for tra ctor 9 engine certification based on the real world is ano ther 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 engin e 15 and tractor applications should be stringent to pro vide 16 a strong incentive for manufacturers to make measur ed 17 sustained investment in efficiency technologies ove r 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 vocationalHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 57 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 th e 4 diesel gasoline balance of vocational vehicles. Fu el 5 efficiency requirements for heavy duty gasoline pic kups 6 and vans should be more consistent with their light 7 duty counterparts. As proposed, the weight adjuste d 8 fuel economic target for the Ford 250 heavy duty pi ckup 9 truck in model year 2025 will be 33 percent lower t han 10 the target for the Ford 150 light duty pickup, with 11 similar engine and transmission aspects. Such a la rge 12 discrepancy in fuel efficiency targets for light an d 13 heavy duty pickups could result in market distortio ns 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 b e 17 required for heavy duty pickups and vans. And numb er 18 five, the Phase 2 standards proposed for 2027 can a nd 19 should be moved forward to 2024. Most of the fuel 20 saving technologies needed for Phase 2 compliance a re 21 available in the market today, and they will be 22 available within in the next few years.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 58 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 p hase 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 t o 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 fue l 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 thi s 19 segment. Those trucks include the Class 2 through 5 20 variants of our popular Ram pickup and our Class 2BPro 21 Master commercial vans. Our gasoline engines inclu de 22 the award-winning 3.6-liter Pentastar V6, and the 5 .7-Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 59 1 and 6.4-liter Hemi V8 engines. Diesel engines incl ude 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 to day 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 veh icle 8 segment. We fully support and commend this 2019 9 through 2027 model year Phase 2 initiative as we di d 10 the collaboration that produced the national Phase 1 11 rule. FCAUS remains committed to the proliferationof 12 clean technology and reducing vehicle operating cos ts 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 progr am, 17 a single national program holds out the promise of 18 delivering environmental and energy benefits, cost 19 savings, and administrative effectiveness that migh t 20 not be available under a less coordinated approach. 21 FCAUS unequivocally agrees. 22 While we are still analyzing the proposed rule , IHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 60 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 functional ity 4 of these work trucks. Payload and towing capacity are 5 important to the owners of these work trucks. Thes e 6 work factor-based standards acknowledge the inheren tly 7 higher greenhouse gas emissions and fuel consumptio n of 8 higher capability vehicles. 9 While the light duty fleet has been regulated 10 under NHTSA's Café Program for roughly 40 years, weare 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 rea l 14 data, it is concerning that there have been calls f or 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 rang e of 21 duty cycle so the values of the different technolog ies 22 vary from a customer perspective.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 61 1 We're challenged by year-over-year stringency 2 increases with effectively only two products, a pic kup 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 increas ed 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 unkno wns 11 at this point. Additional technology will be neede d 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 cylin der 15 deactivation and cool EGR in today's vehicles, maki ng 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 pl ace 20 more clean and fuel efficient vehicles on the road 21 quickly and at a lower cost. Our resources are bes t 22 utilized when applied to one single national standa rdHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 62 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 th e 8 Light Duty Program and recognize the added greenhou se 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 tradin g, 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 the se 17 processes more efficient in the second phase of thi s 18 program. 19 In closing, FCAUS will continue reviewing the 20 proposed rule and submit these and other comments a s 21 part of the formal rulemaking process. We will wor k 22 with EPA and NHTSA and other stakeholders to ensureHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 63 1 that an implementable rule is finalized on schedule . 2 Thank you. 3 MR. TAMM: Thank you, Mr. Oshnock. Ms. Nichol s? 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 a re a 8 community of more than half a million moms and dads who 9 are fighting for clean air and a safe climate for o ur 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 a nd 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 directi on 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 indicat ing 22 that he will likely have outdoor allergies like hisHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 64 1 father and I do. With the increase in extreme weat her 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 o zone 5 alerts, my symptoms get worse. 6 I don't want my child to be that miserable andnot 7 to be able to go outside and have a normal childhoo d 8 where he can play. I see him get knocked around by 9 every virus that rolls through like a typical toddl er 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 chil d'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 n eck 17 of the woods. In Illinois, the rate of childhood 18 asthma is at 13 percent, which is one percent highe r 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 positi veHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 65 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 barre ls 5 every two days. By not burning that oil, the Unite d 6 States would over the lifetime of trucks affected b y 7 the rule avoid one billion metric tons of global 8 warming emissions. That's roughly equivalent to th e 9 emissions created by powering all U.S. households f or a 10 year. That creates not only cleaner air, but a fut ure 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 standar ds 14 to be strengthened to achieve 40 percent fuel savin gs 15 by 2025. If the final proposal is strengthened in this 16 way, it would save an additional 200,000 barrels ofoil 17 per day and avoid an additional 40 million metric t ons 18 of global warming emissions annually, which is the 19 equivalent to shutting down 12 coal-fired power pla nts. 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 moreHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 66 1 efficient, and I urge you to finalize stronger 2 standards that reduce trucks' fuel use by 40 percen t 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 sp eak 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 90/9 4. 11 The proposed clean truck standards will make o ur 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 p uff 17 of Advair with only being home for seven hours. Th at 18 was just last night. Imagine living with it for 18 19 years. 20 Imagine waking up and your child tells you tha t 21 she can't breath. That was my mom's experience whe n I 22 was 10, and she gave the standard medication: aHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 67 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 predniso ne, 5 and that didn't work. So she rushed me up the stre et 6 to the hospital advocate. And in the process of tr ying 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 beca use 12 you're not close to your breathing treatment, and y ou 13 won't be home for a while. I wasn't able to play 14 sports in high school because my asthma is extremel y 15 hard to control. I wanted to run track, but I knewmy 16 asthma would cause me to quit. 17 Reducing diesel emissions should be a number o ne 18 priority. I've had the pleasure to walk outside an d 19 breathe in the fresh and have to take a puff of inh aler 20 in order to breathe normally from the toxic fumes t hat 21 are in the air. I urge everyone to wake up to the 22 reality that people are suffering, and so are yourHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 68 1 children. 2 This can stop, but thank you for listening. 3 MR. TAMM: Okay. Again, thank you very much f or 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 toda y's 9 hearing on the Administration's proposal to increas e 10 the fuel economy and GHG standards for medium and h eavy 11 duty truck vehicles, and engines, and light duty wo rk 12 trucks, and to establish new truck/trailer mandates

. 13 ATD represents some 1,800 franchised commercia l 14 truck dealerships that sell new and used motor vehi cles 15 and engage in service, repair, and part sales. 16 Together, truck dealerships employ more than 100,00 0 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, andHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 69 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 an d 5 NHTSA for taking the time last year to visit severa l 6 truck dealerships, including my store in Grand Rapi ds, 7 Michigan. 8 During my short time today -- with you today, I'll 9 focus on just a few key high-level issues of partic ular 10 importance to truck dealerships. ATD intends to 11 provide more detailed comments and suggestions in o ur 12 written submittal. Specifically, I'll focus on whyany 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 andEPA 22 to move forward with the second round of commercialHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 70 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 t his 4 rulemaking will foster continuous improvements in f uel 5 economy and GHG emissions performance while preserv ing, 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 efficien t 11 equipment. Consequently, your goal should be to hi t a 12 regulatory sweet spot by setting performance standa rds 13 that result in new products that purchasers are wil ling 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 st ores 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 essentialto 21 meet their specific work and duty cycle needs. 22 Nonetheless, although fuel economy performance willHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 71 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 significan tly 11 more. However, the vast majority of prospective ne w 12 truck buyers are businessmen and women who rational ly 13 pencil up front costs of vehicle features, especial ly 14 during times when credit is relatively tight and th eir 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 pas s 18 economic muster. Remember my customers have option s. 19 Instead of choosing to buy new, cleaner, greener 20 equipment, they can instead pay my service and part s 21 operations to help them keep their existing vehicle s on 22 the road up to and including rebuilding engines orHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 72 1 vehicles. Alternatively, they can buy used trucks or 2 tractors that meet their needs at lower cost than t he 3 equipment covered by new mandates. Any new mandate s 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 t he 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 mone y. 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?Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 73 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 1 936 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 f rom 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 mill ion 11 members and supporters of the Sierra Club, my MBA f rom 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 de aler 16 in the country, and other both domestic and importe d 17 products will provide the adequate credibility for my 18 comments. 19 You've already heard and will continue to heara 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 th atHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 74 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 implementi ng 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 ha s 7 suffered also from asthma and has had many of the s ame 8 circumstances as you. And as you know, it is 9 distressing to get on the highway and not know whet her 10 you're going to be able to breathe because you're 11 driving behind a heavy duty vehicle or a bus that i s 12 spewing out diesel emissions. 13 It's also for my family are winners since we o ften 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. An d 17 it's also -- winners are all the other people who h ave 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 definitelyHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 75 1 benefit. Chicago is ground zero with the highest r ates 2 of asthma in the country, especially on the South S ide 3 of Chicago with the highest incident rate of emerge ncy 4 room admissions due to asthma. Society, of course, 5 will benefit from better public health and, becauseof 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 paren ts 10 usually also has to miss work to take care of the c hild 11 at home creating absenteeism and loss of productivi ty. 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 fu el. 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 Fede ral 22 budget will benefit from not having to have as big aHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 76 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. Everybo dy 4 is a winner. I've been in the car business for my 5 entire career, and I have seen regulations promulga ted 6 over and over again, and industries protesting that 7 they will suffer and that we'll be driving econobox es. 8 That has never, ever happened. We've got incredib le 9 fuel economy, huge trucks, unbelievable MPG -- I me an, 10 horsepower in our vehicles. And I think it's time that 11 we get on with this and get it over with, make thes e 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 t he 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 healthHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 77 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 significa nt 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 us e 8 and its impact on the environment. This proposal 9 provides an opportunity to improve upon the first p hase 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 rulemak ing 14 process, and we will continue to do so to ensure th at 15 these regulations are based on the best available 16 science. Our analysis of the technologies that cou ld 17 be cost-effectively applied over the next decade 18 indicates that the average fuel consumption from ne w 19 trucks in 2025 could be reduced by 40 percent compa red 20 to trucks in 2010. 21 The agencies' proposal of a 36 percent improvement 22 by 2027 falls well short of what this analysisHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 78 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 sti ll 4 many aspects of the rule that should be improved. 5 First and foremost, waiting until 2027 to full y 6 implement the level of stringency that the agencies 7 have proposed is unnecessary. There is ample evide nce 8 that the technologies needed to comply with the 9 stringency in the proposed alternative are either i n 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 Institu te, 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 i n 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 agenci es 22 should not extend the timeline of the rule out to 2 027,Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 79 1 2029 without using this additional lead time to 2 increase the technology adoption and improve techno logy 3 effectiveness significantly beyond what is currentl y in 4 the proposed alternative. 5 There are also specific areas where we believethe 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 en gine 17 standard, one which is roughly two to three times l ower 18 than what could be accomplished by 2027. While the 19 engine test cycle has been improved to more accurat ely 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 tra ctorHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 80 1 trailers in the timeframe of this rule. 2 Another area of the proposed standards that ne eds 3 further adjustment are the regulatory targets for 4 vocational vehicles. The agencies have improved th eir 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 impr oved 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 provisio n, 14 which will increase the flexibility for both primar y 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 ref lect 20 the full range of improvements available to these 21 vehicles. The agencies have underestimated the fue l 22 reduction potential of both conventional technologi es,Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 81 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 stan dard 5 that is significantly weaker than what can be achie ved 6 by 2027. Such a standard will not help drive 7 technology investment, nor will it expand the offer ing 8 of efficient vehicles for the fleets that need them . 9 As in the case of tractor engines, the agencies app ear 10 to be lagging what the industry is already on trackto 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 an d 16 vocational vehicles. Achieving a 40 percent 17 improvement by 2025 would save an additional 200,00 0 18 barrels of oil per day in 2035 compared to the prop osed 19 rule. It would also bend the curve on emissions be low 20 today's levels in spite of future increases in good s 21 movement by a truck. That is the level of advancement 22 we would expect this regulation to achieve.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 82 1 We will continue to engage with the agencies t o 2 provide further data to strengthen the rule and ens ure 3 that we can achieve the maximum technology feasible , 4 cost-effective reductions in this sector. Thank yo u. 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 dut y 10 truck segment, cylinder deactivation and cooled EGR , 11 you said this is in place in today's vehicles, maki ng 12 these technologies unavailable for Phase 2. Can yo u 13 explain that, please? 14 MR. OSHNOCK: They're in the heavy duty segmen t. 15 If I said "light duty," I misspoke. We have them o n 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 daughte rs 21 for taking the time to come here. I know you're no t 22 paid to present your testimony, and so it makes it evenHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 83 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 fo r 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 th at 11 you think that the new procedures undermine real wo rld 12 improvements? Did I get that right? Can you expla in 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 ach ieve 21 in this timeframe based on a weak engine performanc e. 22 And so, that leads to a weak tractor trailer standa rd.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 84 1 That's what I meant. 2 MR. GRUNDLER: Okay. If you could elaborate o n 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 Ch ris 11 just said, that we are certainly eager to hear your 12 comments, but saying that technology is available i n 13 the marketplace now does not do it. We will need t o 14 know penetration rates, what it will cost, needed l ead 15 time, how that relates to manufacturers' design cyc les. 16 We'll need -- you know -- 17 MR. COOKE: Yeah, absolutely. 18 MR. SILVERMAN: We're very happy to listen, bu t 19 that's the nature of the -- what we need to be toldto 20 understand. 21 MR. COOKE: Absolutely. I mean, EPA and NHTSAdid 22 an exceptional amount of research, and there's a lo t ofHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 85 1 technical information in the rule. 2 MR. SILVERMAN: And we'd like to think it's qu ite 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 take s 12 that most influences ozone are the ambient standard s. 13 There's a pending proposal to decrease the level ofthe 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 questi ons. 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, thenwe 22 will take a 15-minute break I believe it is. Yeah, 15-Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 86 1 minute break. 2 MR. GRUNDLER: Welcome, panel three. First upis 3 Erin Roth from Wabash Trailers. Welcome. Thank yo u 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 unableto 8 be here today, so I'm here in his stead. But he se nds 9 his regards. 10 Wabash National Corporation thanks the EPA and 11 NHTSA for allowing the allowing to comment on the j oint 12 proposed rulemaking Phase 2 greenhouse gas emission s 13 standards and fuel efficiency standards for medium and 14 heavy duty engines and vehicles. In addition to th is 15 testimony, we do intend to submit formal written 16 comments with more detail for many of the things th at I 17 highlight today. 18 Wabash National is a publicly-traded, diversif ied 19 manufacturer headquartered in Lafayette, Indiana, a nd 20 it's North America's leading producer of semi-trail ers, 21 having shipped more than 57,000 trailers in 2014, a nd 22 an expectation to ship an even greater number in 20 15.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 87 1 With today's just in time environment, semi-traile rs 2 are vital to keeping the U.S. economy moving, and t hey 3 deliver nearly 70 percent of all freight tonnage. 4 Wabash National continuously seeks innovative 5 solutions to improve fuel efficiency on trailers an d 6 lower operating costs for our customers. We suppor t 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 go od 10 thing. Not only are sensible fuel efficiency solut ions 11 good for our air quality, but they help to conserveour 12 fuel resources and have the potential to contributeto 13 the decrease and the cost of freight transportationby 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, vehic le 21 durability and safety, and driver behavior. Thus, to 22 achieve overall improvements in freight efficiency,Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 88 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 see k to 4 maintain and approve state and Federal highway syst ems, 5 to maximize the freight capacity hauled on any one 6 tractor trailer load, for example, the measures tha t 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, includin g 11 these Phase 2 proposed rules, will depend, however, on 12 adopting easy to implement policies that the comple xity 13 of the truck industry and the need for flexible 14 solutions. And so, Wabash National urges the EPA a nd 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 t o 20 popular belief, a semi-trailer is much more than ju st a 21 box on wheels. Most trailers are designed for a 22 specific freight application and are custom built f orHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 89 1 each customer. Additionally, trailers are federall y 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 restric tive 5 Federal regulations. 6 As a result of these regulations, today's 7 solutions for improving fuel efficiency rely on dev ices 8 that are attached to the trailers. Our customers do 9 not simply accept the addition of these devices andthe 10 resulting additional costs without proof that they will 11 definitely result in greater overall freight effici ency 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 no t 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 nothin g 22 but van semi-trailers will not see benefits from th eHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 90 1 adoption of aerodynamic devices. This is because t hese 2 types of trailers and fleets might operate in diffe rent 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 requiremen ts 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 particula r 13 types of trailers or fleets whether through a fleet 14 exception approval process or by including an exten sive 15 list of trailer characteristics that would define a n 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 w ith 21 these regulations as a manufacturer rely on our 22 customers accepting the additional of aerodynamicHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 91 1 devices to the frame of a trailer. If manufacturer s 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 intende d to 10 improve fuel efficiency from Federal excise taxes, 11 exempt the weight of devices intended to improve fu el 12 efficiency from the Federal freight weight limits, and 13 minimize the time, cost, and complexity of complyin g 14 with the reporting obligations under the Phase 2 15 rulemaking. 16 While we would prefer that compliance be volun tary 17 based on our industry's history of proactive 18 introduction and adoption of aerodynamic and weight 19 saving innovations, and request the consideration o f 20 this fact, we acknowledge that there will be a trai ler 21 requirement. And absent a voluntary program, requi red 22 adoption is preferred over an unmanageable averagin gHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 92 1 compliance approach. 2 As a technology leader in the semi-trailer 3 industry, Wabash National welcomes any technology t hat 4 assists our customers in improving overall freight 5 efficiency. We support the goal of improving overa ll 6 fuel efficiency, and welcoming -- and welcome 7 continuing to work together -- fleets, manufacturer s, 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 origina l 16 modern environmental energy activists ever since ar ound 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 wa sHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 93 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. Unfortunatel y, 5 we have not taken all the necessary actions fast en ough 6 to really deal with human-induced climate disruptio n, 7 and the climate clock is ticking. There is a senseof 8 immediate urgency inherently built into our current 9 situation, which requires that we do much more of t he 10 right things at a quicker pace. 11 First off, I will offer my congratulations. T hank 12 you for proposing the standards to make newer heavy 13 duty vehicles more fuel efficient in the first plac e. 14 Secondly, I will offer my constructive criticism fo r 15 improvement. The heavy duty vehicle fuel economy a nd 16 carbon emissions standards should be made even stro nger 17 in order to achieve about 40 percent in fuel saving s by 18 2025. This would use cost-effective technologies t hat 19 are now being deployed or demonstrated. An additio nal 20 40 million metric tons of climate disrupting pollut ion 21 would be avoided each year by 2035, which would be the 22 equivalent of closing down around 12 coal-firedHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 94 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 a nd 5 cargo vans is that they comprise a no regrets 6 transportation energy efficiency strategy. Besides 7 promoting climate protection, they will also have o ther 8 positive benefits, like cutting our oil consumptionby 9 an additional 200,000 barrels each day in 2035; 10 reducing hazardous air pollutants from idling truck s 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 gr een 15 energy innovation for inherently cleaner heavy duty 16 vehicles. 17 In conclusion, taking my advice and strengthen ing 18 the final heavy duty vehicle economy and carbon 19 emissions standards even more will improve our publ ic 20 health, ecological health, economic well-being, and 21 energy security. That concludes my testimony. Tha nk 22 you.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 95 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 Emission s 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 f rom 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 technolog y 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 mobil eHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 96 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 ha s 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 wil l 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 eng ine 19 and vehicle standards included in the Phase 2 propo sal. 20 This framework developed for the Phase 1 standards 21 ensures the continued important testing linkage bet ween 22 engine criteria and greenhouse gas emissions, andHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 97 1 ensures that manufacturers deliver durable, enforce able 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 certa inty 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 p er 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 sl ip 18 catalysts with high selectivity for nitrogen format ion, 19 and efficient urea dosing technologies. 20 MECA supports the proposal to close the curren t 21 emissions loophole on truck glider kits. The legac y of 22 dirty diesel engines on America's roads needs to pu t inHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 98 1 our rearview mirror. All new trucks need to utiliz e 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 option s 6 off the table. 7 MECA also believes that future auxiliary power 8 unit particulate emissions should be controlled thr ough 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 t hese 16 engines. 17 Finally, MECA believes that significant furthe r 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 improveme nts 22 to the growing suite of advanced diesel exhaustHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 99 1 emission control technologies that include higher c ell 2 density, low thermal mass substraits, improved SCR 3 catalyst systems coded directly on filter substrait s, 4 and advanced oxidation catalysts that include passi ve 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 nearl y 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 l ow 12 NOx emissions and improved fuel efficiency. And we 13 believe that these optimizations can continue in th e 14 future to allow diesel engines to further reduce bo th 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 testHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 100 1 cycle, and to improving NOx emission performance inlow 2 temperature duty cycle operations. 3 MECA asks EPA to initiate a rulemaking that wi ll 4 further reduce NOx emissions from heavy duty engine s as 5 soon as possible to allow manufacturers to work wit h 6 their customers on delivering fully optimized futur e 7 engines that deliver improved fuel efficiency and u ltra 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 Matthe w 13 Rudnick. I am manager of Global Fuel Economy and 14 Greenhouse Gas Policy at General Motors. I'm pleas ed 15 to speak with you today regarding the EPA and NHTSA 16 Noticed of Proposed Rulemaking to address greenhous e 17 gas and fuel efficiency for medium and heavy duty 18 trucks. 19 General Motors is a major manufacturer of thes e 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 bothHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 101 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 i s 5 paramount that it be consistent with some critical and 6 foundational principles. 7 First, it's imperative that NHTSA and EPA deve lop 8 a harmonized approach that does not penalize both 9 consumers and manufacturers in providing products t hat 10 will continue to serve the purposes, functions, and 11 utility that are needed. General Motors is support ive 12 of the approach used during Phase 1 of this initiat ive, 13 and encourages the continued harmonization of the c afé 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 wi th 17 the emission reduction standards put in place. 18 Second, the program must continue to recognizethe 19 unique functionality and utility needs of the truck ing 20 industry, and that we provide vehicles that preserve 21 the performance integrity of these work trucks. 22 Consumers value the payload and towing capabilitiesHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 102 1 that these working vehicles offer, and the work fac tor2 based standards set by EPA and NHTSA should continu e to 3 align with the industry and business needs of this 4 demographic. 5 Third, we have been gaining valuable experienc e 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 conditione rs. 14 These incentives are now paving the way for an ear ly 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 provision s 20 led to the expansion of this approach in 2014 for t he 21 light duty fleet with the introduction of an expanded 22 off cycle list of pre-assigned and pre-approved cre ditsHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 103 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 C lass 7 3 pickups and vans covered by this proposed regulat ion. 8 We have also had favorable experience with the 9 extended carry forward time allowed in the light du ty 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 earne d 14 through their early actions. This concept could al so 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 Propose d 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 optimize d by 21 American consumers. We cautiously support this pat h 22 based on Alternative 3 for future emission reductio nHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 104 1 standards. This path will challenge our product pl an 2 and drive considerable technology into our heavy du ty 3 trucks and vans. 4 Finally, the program must attempt to minimize the 5 potential for unintended consequences, especially f or 6 the consumer. The heavy duty fleet does not benefi t 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 onlynow 10 being accumulated and analyzed for the 2014 model year, 11 which is the first year of Phase 1 of the medium an d 12 heavy duty truck regulations. 13 Year-end reports for 2014 were due to EPA by t he 14 end of March 2015, so this first year of comprehens ive 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 b oth 18 Phase 1 and the proposed Phase 2 of the heavy duty 19 regulations. 20 We will providing more extensive written comme nts 21 to address the key details that fundamentally crop up 22 with the implementation of any new program. We loo kHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 105 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, an d we 8 have basically four comments regarding the proposed 9 changes regarding what has been referred to broadlyas 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 tha t 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 woul d be 19 an appropriate threshold. 20 Therefore, Terex proposes that if the EPA sets 21 limits on the quantity of gliders produced, it shou ld 22 not be based solely on the number of employees theHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 106 1 glider manufacturer has, but should also be based o n 2 the number of on highway vehicles it produces simil ar 3 to the way the off highway transition program for 4 equipment manufacturers is set up. 5 For example, Terex Corporation has approximate ly 6 20,000 employees globally, but only approximately 2 20 7 are involved in the manufacturer of gliders at one 8 small facility located in Fort Wayne, Indiana. Sho uld 9 the proposed regulations continue unchanged, it wou ld 10 result in the redundancy of some 70 team members atthe 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 2 014, 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 "gl ider 18 kit" means "any other new equipment that is intende d to 19 become a motor vehicle with a previously used engin e, 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 reque stHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 107 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 agen cies 9 on that. The proposed limitation on gliders doesn' t 10 distinguish between repaired vehicles and glider ki ts. 11 Terex suggests that language be added that allows for 12 a used powertrain to be installed onto a new chassi s 13 for the case of repairing a damaged vehicle, and no t be 14 subject to regulations that are newer than the orig inal 15 bill date of the damaged vehicle. 16 And then my final comment number four is regar ding 17 page 40186. It says that six by six and eight by e ight 18 vehicle configurations are only manufactured for 19 specialized vehicles that require extra traction fo r 20 off road applications. They are very low volume sa les, 21 and their increased fuel consumption and CO2 emissi ons 22 are not significant in comparison to the overallHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 108 1 reductions of the Phase 2 program. 2 Therefore, Terex suggests that vehicles with s ix 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 thatis 8 premature compared to the engines that were designe d 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 befo re 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 Gustaf son. 20 I work with children and adolescents. I say that 21 because I think you'll hear their voice in my littl e 22 spiel.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 109 1 I'm going to start this with an insult and the n 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 stan d up 17 to deniers and declare "enough of your self-interes ts." 18 As a species, we can only survive when truth commi tted 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 remindi ng 22 us all why we're doing this work. Ms. Rondeau,Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 110 1 welcome. 2 VICE ADMIRAL RONDEAU: Good morning, and I tha nk 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 i n 6 2012, and frankly I've had two tours here in Illino is. 7 One was I was the commander in charge of all of th e 8 recruit training up north of here in the Great Lake s, 9 and as a three-star I was the deputy combatant 10 commander down at Scott Air Force Base for the Unit ed 11 States Transportation Command. And that particular 12 command is a joint functional commander that suppor ts 13 all the distribution and transportation needs of th e 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 withoutmy 18 command knowing that. And so, I come to you with t hat 19 personal experience. 20 I also, though, come as the voice to the Milit ary 21 Advisory Board. This is a board comprised of retir ed 22 three- and four-star admirals and generals who haveHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 111 1 spent over a decade studying the science, the data, and 2 the policies with regard to environmental issues an d 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 jus t 7 mine, but I come with mine with regard to the lens of 8 experiences that I bring to this issue. And I'm dr iven 9 by the fact that there's a battlefield voice to thi s 10 issue. Since World War I, we have been a mechanize d, 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, mo re 14 maneuverable. But the one thing that has not chang ed 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 j ust 21 a fleeting imperative; it is a national imperative need 22 and requirement and imperative.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 112 1 For us, fuel efficiencies for things like 2 generators and heavy duty trucks is really importan t 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 i ssue 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 n eed 17 here and an imperative to make this a more efficien t 18 set of rules that would lead then to better and mor e 19 efficient vehicles. 20 There's also the cost. When we talk about cos ts 21 in the military for oil and gas and fossil fuels, i t is 22 not just the cost of the commodity. It's a fullyHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 113 1 burdened cost, which is not only the price of the o il, 2 the gas, it is also the entire life cycle cost to g et 3 the gas from point of sale to point of effect, from 4 point A to point B. This is an enormous cost to th e 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 th is 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. Th ank 20 you for lending your voice as well as for your serv ice 21 to your country. I've got one question for Ms. Rot h. 22 Your testimony -- your testimony noted that your fi rmHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 114 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, mo re 4 efficient products, and allows them to fully amorti ze 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 bu ilt 11 on specs that are set by particular customers. So 12 while in theory averaging would allow us to, you kn ow, 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 mixin 22 a particular year of several customers who areHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 115 1 insisting that because of whatever their applicatio n is 2 they don't want to accept these devices, we will ei ther 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 ve ry 6 low margin industry like the trailer industry, we'r e 7 going to eat the cost of the aero devices that we w ould 8 stick on that customers wouldn't necessarily want i n 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 pushedout 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 t o us 16 what we are supposed to build by the customers and we 17 don’t have the flexibility there, this doesn't real ly 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 w ould 22 be a big help. Thank you.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 116 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 speci fic 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 beor 7 definitions would be of what could be exempted? 8 Certainly ideas on that sort that you might have wo uld 9 be -- would be valuable. 10 MS. ROTH: We will certainly elaborate on that 11 within our formal comments that we'll submit, but f or 12 purposes to respond to you today, we think some of the 13 devices that you have noted in the rule as work dev ices 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 t hat 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 criter iaHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 117 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 previo us 7 witness who suggested that there should be less lea d 8 time to apply engine and vehicle standards to glide r 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'r e 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 sh ort 18 break now. We will reconvene at 11:30. Thank you very 19 much. 20 (Break.) 21 MR. GRUNDLER: Before we get started with pane l 22 four, I want to recognize we have in the audience t odayHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 118 1 the architect of the Phase 1 rules. Chet France ha s 2 joined us. Welcome, Chet, wherever you are. So ifyou 3 didn't like Phase 1, go to find Chet. He's somewhe re 4 in the back of the room. And we're going to try toget 5 him on one of the subsequent panels. 6 MR. TAMM: And for those who may have joined s ince 7 we walked through some opening remarks, we're basic ally 8 inviting the panel who will come in after the panel 9 that's currently up front to sit on seats on the si de 10 here. So I'll read off who is in the upcoming pane l as 11 well. And for all of the people who are commenting 12 today, we've got a guide here, a timer guide, whichit 13 basically it's set for five minutes. So the red li ght 14 will come on at five minutes. There will be a gree n 15 light for the first four minutes, and a yellow ligh t to 16 let you know when there's one minute left. 17 So the panel individuals, if we could ask to g o 18 over to the staging area: Michael Zurakov, Rashunn a 19 Delaney, Patti Perry, Karen Fort, Robert Natkin, To ny 20 Fuller, and Jan Franklin -- Frankel. Sorry. So ifyou 21 could proceed to the -- there's seats over here. I f 22 you could proceed to that area, then that'll -- the re'sHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 119 1 a little bit of prep work with getting cards togeth er. 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 o f 7 the Diesel Technology Forum. We are a non-profit 8 educational organization that represents the leader s in 9 clean diesel technology, including engine vehicle a nd 10 equipment manufacturers and affiliated organization s. 11 Thank you for the chance to appear today and commen t on 12 these proposed rules. 13 Today manufacturers of commercial trucks, engi nes, 14 and their components produce the cleanest, safest, and 15 most fuel efficient technology in the world. For a ll 16 parties, the challenge of further increasing fuel 17 efficiency while maintaining or improving environme ntal 18 safety and productivity of commercial vehicles is a s 19 important as it is complex. 20 Diesel engines are the prime mover of the glob al 21 economy and the primary power plant for the wide ra nge 22 of commercial trucks under discussion today. We ho peHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 120 1 that the outcome of these proceedings sets the stag e to 2 build on the success already accomplished in achiev ing 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 commer cial 8 vehicles and the transformation to clean diesel 9 technologies; secondly, the clean air fuel saving a nd 10 other benefits accruing; and third, a framework for 11 continued success. 12 First, new clean diesel technology will contri bute 13 to further efficiency gains and continue to be the 14 primary power train for commercial vehicles. Advan ces 15 in diesel engines are a key part of this Phase 2 16 rulemaking, and we fully anticipate they will conti nue 17 to contribute to that overall efficiency gain desir ed 18 by the rule. Diesel is going to continue to be the 19 power plant of choice because it offers an unmatche d 20 combination of power, increasing energy efficiency, 21 work capability, reliability, and now near zero 22 emissions environmental performance, along with anHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 121 1 ability to utilize a variety of low carbon renewabl e 2 diesel fuels. 3 Since 2000, the leaders in clean diesel techno logy 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 th e 10 two major reasons for the clean air progress observed 11 nationwide in 2014. These new technology clean die sel 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 registratio n 16 data, right now there's about 37 percent of all the 17 commercial trucks on the road are 2007 and newer, a nd 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 fiveHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 122 1 nationwide for the 2010 and newer vehicles. So her e, 2 that means 40 percent on the roads in Illinois toda y 3 are 2007 and newer. 4 Last year was a very strong year for the secto r. 5 Over 186,000 new medium duty trucks were sold, Clas s 4s 6 through 7, along with 230,000 heavy duty Class 8 tr ucks 7 sold. The overwhelming majority of these were powe red 8 by clean diesel with just a few thousand units powe red 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 introduct ion 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 sh ows 19 that the technologies on the road today have already 20 reduced by nine million tons of CO2 about 880 milli on 21 gallons of diesel fuel. That's 21 million barrels of 22 crude -- 1.45 million tons of NOx -- have already b eenHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 123 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 conversatio n 5 this week. And the NOx emissions from 158 coal-fir ed 6 power plants. So you can see we are already making 7 significant impacts in reducing carbon emissions an d 8 NOx. 9 Regarding vehicle technologies and what's goin g to 10 be happening in Phase 2, I’d like to say a few word s 11 about things that are not covered under this rule, the 12 first being renewable diesel fuels. This rule focu ses 13 on vehicle and engine standards, but does not get i nto 14 fuels. We believe that looking at the use of renew able 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. Ju st 18 this week, UPS announced that they plan to use 46 19 million gallons of renewable diesel over the next t hree 20 years. 21 I’d also like to encourage that we think about 22 expanding the consideration beyond just making newHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 124 1 engines and vehicles cleaner and more efficient, an d to 2 looking at the existing population of trucks, and h ow 3 they're operated, and encourage the introduction ofnew 4 technology diesel engines. Finally, there's a 5 framework for continued success. You're all famili ar 6 with this, and I think other commenters have touche d on 7 these: a national program, adequate lead time, neu tral 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 ma y 13 look and perform somewhat differently and may be 14 burning different kinds of low carbon fuels. But i n 15 the end it will still be a diesel engine and an 16 integral component of meeting the needs of a growin g 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 opportunitytoHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 125 1 provide testimony this morning. The Center for 2 Neighborhood Technology, CNT, we're a 40-year-old n ot3 for-profit organization, but we do projects that 4 demonstrate and research environmentally beneficialnew 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 Scientis ts 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 b asic 13 reasons that might not have been -- might be overlo oked 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 patt ern 19 since the recession in which car driving automobileVMT 20 has been declining. It's flattened out in the lastfew 21 years. It's now going into a slight decline. At t he 22 same time, truck use has been increasing more or le ssHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 126 1 in proportion to the rise in GNP. So as this patte rn 2 continues, what we can expect to see is a greater n eed 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 t he 9 development of businesses, industrial and logistics 10 businesses, distribution businesses, around intermo dal 11 freight terminals. If we had the best possible met hods 12 of reducing emissions from trucks, we would still f ind 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 th at 16 depending on three to seven times more efficient pe r 17 ton mile movement of freight when moving the freigh t by 18 rail. 19 And intermodal freight had made significant ga ins 20 in reducing and generating savings through mode shi ft. 21 The amount of volume of containers that's moving b y 22 intermodal has risen from a little than six milliontoHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 127 1 over 13 million just over the last 20-year period. And 2 as this has happened, intermodal terminals have bee n 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 ta lk 10 about potential for zero emission ports, zero emiss ion 11 intermodal terminals despite the fact that the 12 railroads still have a long way to go to improve th eir 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 invo lved 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 wher e 22 there's already an existing industrial base, placesHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 128 1 where workers can get to. 2 And consequently, these facilities are often 3 relocated in exurban locations, which creates a who le 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 an d 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 ju st 12 like to point out that as the standards are introdu ced, 13 we recognize that the nature of the standards is th e 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 ma ke a 20 statement today. May name is Brian Urbaszewski, an d I 21 work for Respiratory Health Association founded in 1906 22 in Chicago. We work to prevent lung disease and toHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 129 1 promote lung health through research, advocacy, and 2 education. 3 We're thankful for the immense progress made i n 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 increa ses 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 h as 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 th e 19 cleanup of the emissions from long-lived diesel eng ines 20 that pre-date EPA's stringent standards, new challe nges 21 have arisen. It's become increasingly clear that 22 global warming is a health threat, particularly toHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 130 1 people living with lung disease. 2 Increasing heat waves put people with limited lung 3 capacity at higher risk of hospitalization and deat h. 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 grea ter 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 increas e 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 wildf ire 16 on the Canadian triggered air quality alerts here i n 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 warmingare 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 th oseHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 131 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 globa l 4 warming. Reducing fuel consumption through greater 5 efficiencies and through the development of non-fos sil 6 fuel technologies that eliminate carbon emissions a re 7 needed to address these health threats. For those 8 reasons, we believe strong EPA greenhouse gas tailp ipe 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 shou ld 12 be strengthened, and that EPA should increase its g oal 13 to achieve a 40 percent fuel savings by 2025. 14 The agency can further increase the $37 billio n in 15 health and welfare benefits the proposed rule would 16 bring. The ability to gain additional reductions i s 17 there. The agency should go beyond its very 18 conservative approach to capture additional fuel 19 reductions, a strategy we believe will benefit publ ic 20 health for many years to come. 21 Again, thank you for the time and the opportun ity 22 to speak on this issue today.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 132 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 appreciat e 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 truck s. 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 househol d 12 and my neighbors. The proposed standards will resu lt 13 in significant pollution reduction and increase in 14 health benefits, as my fellow supporters will testi fy. 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 fue l 20 efficiency standards of cars and light trucks has 21 resulted in the present savings of about three to f our 22 million barrels a day in the U.S.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 133 1 Had these standards not been in place, polluti on 2 from an additional billion or more barrels of petro leum 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 prici ng 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 o f 13 fuel. The second global risk factor is a geopoliti cal 14 event up to and including warfare that could disrup t 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 maj or 19 risks to oil and gas prices and supply. First if t he 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 w illHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 134 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 sp read 4 between Brent and West Texas intermediate petroleum 5 prices. The greater risk, however, U.S. natural ga s 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. gaso line 11 and diesel consumer at greater risk. It also 12 neutralizes the premise that shifting heavy truck f uel 13 from diesel to natural gas will be a cost saver wit hout 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 usHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 135 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 o f 4 her career in the banking industry specializing in bank 5 compliance, and currently a bank director at Standa rd 6 Bank and Trust Company in Illinois. And I do 7 appreciate the need for creating and maintaining hi gh 8 quality, enforceable, and effective regulations. 9 I was also the director of North American 10 Sustainability for Bank ABM AMRO, and in that regar d we 11 specialized in providing banking solutions around t oxic 12 and contaminated properties, but also in figuring o ut 13 how to finance the kind of changes that are being 14 talked about today in making previously unfinanceab le 15 projects financeable, and, therefore, possible to 16 achieve. I also watched the effect of climate chan ge 17 in a stint that I did as the deputy superintendent of 18 the Forest Preserve District of Cook County, one ofthe 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-focusedHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 136 1 household. My father's first business was a fillin g 2 station that he ran with his brothers, and he soon 3 thereafter ran an aftermarket vehicle supply compan y 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 ona 7 racing car team. I myself have driven high-performance 8 vehicles my entire driving life. And just five mon ths 9 ago traded in my last one, albeit reluctantly, for a 10 hybrid. 11 My friends and I haul materials, people, anima ls, 12 supplies around in large trucks and trailers for ou r 13 vocations and avocations. And I hope we will alway s 14 have these opportunities for moving ourselves and o ur 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 persona lHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 137 1 level I have suffered from asthma for decades 2 corresponding roughly with the time that I moved fr om 3 rural to an urban area. And it is quite possible t hat 4 my father's untimely death when I was only 29 was due 5 to his long and close exposure to petroleum product s 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 helpfuland 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 inthe 14 middle of the transportation industry here in Chica go, 15 and I have watched, even though my own lifetime, as our 16 air and water have become cleaner through regulatio ns 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 person ally 20 being able to see a female bald eagle and her fledg ings 21 for the first -- who were the first eagles born in Cook 22 County in nearly 100 years. The pollution in our a irHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 138 1 and water and, therefore, in the eagles' food suppl y 2 did not allow female eagles to produce eggs that we re 3 not crushed when she sat on them. We can make thes e 4 improvements, and that's why I hope these regulatio ns 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 wor k at 8 it day after day after day. 9 The technology already exists for powertrain a nd 10 transmission improvements. An analysis from the Un ion 11 of Concerned scientists show that we can, as was 12 earlier testified, with just a few percentage point s do 13 40 percent by 2025, and I urge you to strengthen th ese 14 proposed regulations. 15 Thank you again for the opportunity to speak t o 16 you. 17 MR. TAMM: Okay. Thank you for your testimony . 18 Could I have you introduce yourself? I wasn't sureof 19 the right pronunciation, and it might be a lot simp ler 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' mHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 139 1 here representing the Sierra Club. And I'm here to day 2 because I'm a young person who cares about the qual ity 3 of the air and protecting the climate. When I firs t 4 moved to Chicago, I lived in the back of the Yards 5 neighborhood near the old stockyards. And when I c ame 6 home from work, I would get off at the 47th Street red 7 line train station, and I would walk down 47th Stre et 8 to my apartment. And the 47th Street stop is righton 9 the Dan Ryan Expressway, and 47th Street over thereis 10 a pretty heavy transportation corridor. 11 And every day when I walked home, I noticed ho w 12 the trucks that would affect my breathing and my he ad, 13 because I suffer from my mild asthma. And walking down 14 that street every day, I would just kind of pause t o 15 think how lucky I was that I had access to an inhal er 16 and other medical services, and thought about how much 17 worse other people in Chicago would have it. Earli er 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 .Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 140 1 And I think that these rules would be a great step in 2 the right direction to curbing the effects of globa l 3 warming right now. People have said today that 4 standards would cut oil use by over a million barre ls 5 every two days under these proposed rules. And ove r 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 mileper 11 gallon standard of trucks haven't changed in decade s, 12 and that their greenhouse gas emissions are 13 disproportionate to their presence on the road rela tive 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 discussin g 17 how the technology already exists to meet these 18 standards, and new standards would help save trucki ng 19 companies money through efficiency and consumers 20 through lower costs, not to mention the huge saving s to 21 our public health through lower emissions, it's jus t so 22 clear to me that we need to take action on this iss ue.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 141 1 A lot of people have been talking about the pr etty 2 historic announcement President Obama made on Monda y 3 about the Clean Power Plan, and he quoted a U.S. 4 governor talking about, "We are the first generatio n to 5 feel the impact of climate change, and the last to be 6 able to do something about it." So ultimately I th ink 7 we can't afford not to enact a common sense initiat ive 8 like this in making our trucks more efficient. AndI 9 urge the EPA to finalize stronger standards that wo uld 10 reduce trucks' fuel use by 40 percent by 2025. 11 Thanks again for the opportunity to speak toda y. 12 MR. TAMM: Okay. Thank you very much, and tha nks 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 c ome 18 forward. Please do. And we'll announce the next 19 panel. Actually once this next panel concludes the ir 20 comments, then we'll break for lunch. 21 MR. GRUNDLER: Mr. Zurakov, when you're ready, 22 please proceed.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 142 1 MR. ZURAKOV: Thank you. I'm Michael Zurakov from 2 Skokie, Illinois. I'm here as a private citizen, a nd I 3 want to acknowledge the support and assistance of b oth 4 the Sierra Club and the Union of Concerned Scientis ts. 5 Without their support and encouragement, I probabl y 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 greates t 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 quickl y, 16 decisively, and globally if we are going to avert t he 17 most catastrophic effects. To that end, we must 18 dramatically reduce greenhouse gas emissions from a ll 19 sources, including the transportation sector. 20 My personal commitment to this has taken our 21 household through several changes. In 2005, we cha nged 22 to a gas/electric hybrid car for everyday use. InHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 143 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 priv ate 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 othe r 10 day and couldn't resist it. Only far-reaching acti ons 11 by policymakers can achieve the serious cuts that a re 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 addr ess 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 f uel 21 costs, which then spreads through the economy. 22 As I understand them, the proposed standards w illHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 144 1 reduce fuel consumption some 36 percent by 2027, 2 resulting in a 2035 savings of 550,000 barrels of o il 3 per day. However, a recent UCS analysis finds that 4 reducing new truck fuel consumption 40 percent by 2 025 5 is both cost-effective and technically feasible. 6 Therefore, the current proposal should be strengthe ned 7 to save an additional 200,000 barrels of oil per da y in 8 2035. The urgency that is the rapidly closing window 9 of opportunity for climate action makes it imperati ve 10 that we reduce emissions as fast and as quickly as 11 possible. 12 Again, I applaud the Administration for propos ing 13 standards to make our trucks more efficient, and I urge 14 you to finalize even stronger standards to the grea test 15 extent feasible. I just hope it's not too late. T hank 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 letti ng 20 me have this opportunity to testify. I am a reside nt 21 of Wilmette and representing Sierra Club. 22 So I wanted to tell you what happened 10 years agoHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 145 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 canc er. 4 So after reading that, I decided promptly I'm goin g to 5 drive him to school. So then recently I went to a Glen 6 View environmental town hall to see has anything be en 7 done about this issue, about diesel exhaust emissio ns. 8 And I talked to legislators and environmental expe rts, 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, the n 13 that is required to have pollution controls. But f or 14 anything 2006 and earlier, which I don't consider t hat 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 o f 20 studies about the harmfulness of diesel and exhaust 21 exposure linked to heart disease, lung cancer, canc er, 22 strokes, and other premature death. In fact, the WorldHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 146 1 Health Organization in 2012 confirmed this. 2 So what I'm asking -- you know, and I also wan t to 3 say not only is diesel bad for all of us, but kids 4 riding these schools because they're young, their l ungs 5 are immature, and they breathe at a quicker rate, s o 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 th e 13 model year 2007, and they said half the fleet of 2, 200. 14 So, again, I was shocked that this has not bee n 15 resolved, and I would like any school bus model 200 6 16 and earlier to have the same requirements and pollu tion 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 aboutit. 21 They're just waiting for these school buses to exp ire, 22 you know.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 147 1 So thank you. I thank you for your time. I t hank 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 allowe d 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 pickin g up 16 on it -- 17 MR. GRUNDLER: That's right. 18 MS. PERRY: -- because I read the letters. Th e 19 EPA was terrific. You know, they're saying we havea 20 grant to retrofit your bus, you know. But, no, the y're 21 not responding because there are no regulations. 22 They're not required to do so.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 148 1 MR. GRUNDLER: That is true. 2 MS. PERRY: Thank you very much. 3 MR. SILVERMAN: I would add the proposal on gl ider 4 kits is to deal at least with rebuilt older vehicle s 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 Fulle r. 14 I'm a volunteer with the Sierra Club here in Chicag o, 15 and have been concerned about the threat posed by 16 carbon pollution and the resulting climate disrupti on. 17 I would like to thank the U.S. EPA and DOT for the se 18 second phase standards to reduce carbon pollution a nd 19 oil use from heavy duty freight vehicles and trucks . 20 However, these standards need to be strengthen ed 21 to achieve at least a 40 percent reduction by 2025. 22 The science shows that the technology exists to doHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 149 1 this. Strong 40 percent reduction standards are wh at I 2 call really a no-brainer decision. Increased standards 3 would yield additional health, economic, and 4 environmental benefits with minimal costs, especial ly 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 Feder al 8 government has been taking in healthcare and the co sts 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-industria l 16 times, to limit the impacts that climate change wou ld 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 dedicate d to 20 analyzing the world's progress, U.S. action plans a re 21 short of what's needed. 22 By increasing these second phase standards to a 40Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 150 1 percent reduction, we could take one step towards 2 limiting the impacts of climate change. Anything e lse 3 endangers not only our own health and economic well

4 being, but the future for our families and the plan et. 5 Thank you. 6 MR. GRUNDLER: Thank you for your comments. M s. 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. A s 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 appreci ate 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 ei ther 20 regulations or carbon tax, or cap and trade, or allof 21 them. Let's do all of them. 22 So I read these standards, and I think, yes, t heyHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 151 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 be tter 5 light bulbs and homes and appliances. But heavy du ty 6 truck fuel economy has barely changed since the 197 0s, 7 okay? I'm 63. I was 18. That's just really stupi d. 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 consumpt ion. 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 whic h 17 never compromise with anybody, and the laws of 18 politics, which is the art of the possible. You ar e 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 p artHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 152 1 of a much larger truly noble ethical enterprise, an d 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 act ion 5 really makes it critical. Frankly I'm scared. The re 6 are unknown tipping points. We are not just talkin g 7 about heat stroke or asthma. We are talking about 8 potentially the death of an ecosystem which support s 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 starv ing 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 stitchin 17 time saves nine, strengthen this standard to 40 per cent 18 by 2025, and if someone has a breakthrough in 19 technology before 2030 -- 20 Now, this law prevents any further changes unt il 21 2030, but if there's a breakthrough, please, could we 22 amend that? Could we please institute all theHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 153 1 technology we've got all the time as fast and as ha rd 2 as we can, because really here this is a matter of life 3 and death. The chips are down. We must push reall y 4 hard. 5 We need an insurance policy. We don't know en ough 6 to be complacent, to have good business alternative s 7 that place no onerous expenses, blah, blah, blah. We 8 can get this at least, even in the political realit ies, 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 n ow. 12 And we can argue against, say, the Supreme Cou rt's 13 objecting that this might place an onerous burden o n 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 mi les 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'sHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 154 1 not too late. There is even economic opportunity f or 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 ma kes 8 what EPA would call mixed fuel systems. We have th e 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 tel l 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 speak ingHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 155 1 about is able to reduce diesel fuel consumption on the 2 order of 50 percent. It's a mixed fuel, which mean s it 3 simultaneously operates with diesel and natural gas at 4 the same time. Now, in doing that we get on the or der 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 tellingyou 9 anything new here. 10 But we do have some questions, and I have a li st 11 of six that I've submitted to you, and I'll go thro ugh 12 them very quickly. 13 We would like to -- as a small volume 14 manufacturer, we'd like to better understand how th ese 15 Phase 2 proposed greenhouse gas rules will be affec ting 16 the OUL and the IUL approval criteria. Question tw o. 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. AsHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 156 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 t he 5 RMC-13 or the heavy duty transient. I'm very famil iar 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 yo u 12 is, how will those vehicle fuel economy improvement s be 13 reflected or in the engine -- the engine dyno test. 14 Are you going to modify, put a correction factor onthe 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 no t a 21 standard type fuel, that extends to 2020, January 1 st. 22 With respect to Subpart 1036.150, the interimHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 157 1 provision -- this is for gasoline engine manufactur ers 2 -- you're taking the small-volume manufacturer 3 exemption to January 2022, and if it's -- you're no t 4 putting gasoline 85 or diesel fuel, that extends to 5 2023. 6 So what that is saying is there's a discrepanc y 7 between the exemption allowed for the heavy duty en gine 8 small-volume manufacturer and the spark ignition en gine 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 no t 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 ca ll 18 it, mixed fuel as you call it, there are things tha t 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 yougo 22 in and redesign the engine. I know how to do it. IHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 158 1 used to do it at Ford. 2 But the small-volume manufacturer converters f or 3 natural gas are not privy to making these significa nt 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 oneand 8 two grams per brake horse power hour. Your regulat ion 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 t o 14 ask you to wrap it up. 15 MR. NATKIN: Yeah, okay. There's issues in af ter 16 treatment that they're not being addressed, and the y 17 are listed in here. 18 My last question which I will ask you to consi der 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 i f 22 there's any consideration for a company that's taki ngHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 159 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 toone 6 of our team outside, we can get you a contact for 7 someone who can explain what we've done, and hopefu lly 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 whe n 13 the fumes from a rolling carbon dioxide factory are 14 enveloping my car. The semi gains on me as I breakthe 15 speed limit trying to get over to the next lane. G o 16 back to normal breathing, but not for long as my no se 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 impresse d at 20 the increased MPG the new 2015s were capable of. T hen 21 the thought struck me: why not make truck 22 manufacturers increase the MPGs on their vehicles? NotHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 160 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 progres s 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 quest ions 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, a nd 22 Ms. Delaney will be our next panel. And up now isHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 161 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 Gordo n, 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 i n 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 w ith 17 EPA and NHTSA regarding the two Agencies' efforts t o 18 address the greenhouse gas emissions and fuel 19 efficiency of medium and heavy duty vehicles. Duri ng 20 this time, we've always been afforded the opportuni ty 21 to directly engage with EPA and NHTSA technical sta ff 22 and management. In addition, Allison has supportedHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 162 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 o n 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 automa tic 8 transmission systems and hybrid systems. We've als o 9 emphasized the importance of assessing the relative 10 performance of vehicles and transmission systems wi th 11 respect to the real world operating conditions of 12 commercial vehicles. 13 It's a considerable understatement to note tha t 14 the Phase 2 rule is a complicated rulemaking. We'r e 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 mode l, 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 t o 21 make GEM more accurate and more representative of r eal 22 world vehicles. We also recognize the use of GEM a s aHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 163 1 primary certification methodology, but we have some 2 significant concerns with the quality of GEM's soft ware 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 go t it 6 to run, there were a number of coding errors 7 identified. Secondly, the model produces unrealist ic 8 operation of the duty cycles. The lockup shift 9 strategy and the neutral loading and automatic neut ral 10 functionality are inappropriate. And finally, ther e 11 are major deficiencies in the base control algorithms. 12 Some production vehicle configurations would not s hift 13 out of first range. Others do not downshift to highway 14 speeds when the load is encountered. We've also se en 15 the GEM controller release lockup at highway speeds 16 which would never happen. 17 These examples do not reflect how fully automa tic 18 transmissions operate, and flaws in GEM will direct ly 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 t heHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 164 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 syst ems. 10 This is especially true in the vocational vehicle 11 market where there are hundreds of different vehicl e 12 types, and is amplified where, as here, EPA and NHT SA 13 intend to decrease greenhouse gases and improve fue l 14 efficiency through the deployment of new technology . 15 When GEM executable files will not run, when o ther 16 errors are found in GEM, when delays occur in makin g 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 arbitra ry. 20 To be clear, we intend our comments not as the 21 reflection of the hard work of EPA and NHTSA or the ir 22 staff. Instead, our criticism is a reflection of t heHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 165 1 extremely complicated nature of the proposed rule a nd 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 ext end 5 the comment period to allow sufficient time to reso lve 6 GEM bugs and to allow the public sufficient time torun 7 the model and fully understand its implications. I n 8 our view, there is no downside to this option since 9 there is no legal deadline for a final rule. Anoth er 10 possible avenue would be to reopen the public comme nt 11 period when GEM is further developed. Other 12 administrative avenues are potentially available, 13 including issuing a notice of data availability wit h an 14 opportunity to comment. 15 Allison Transmission is looking forward to 16 continuing to work with EPA and NHTSA, but we ask n ow 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 consi der 21 this matter before the announced deadline for the 22 submission of comments. Thank you.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 166 1 MR. GRUNDLER: Thank you. Mr. Lackore. 2 MR. LACKORE: Good afternoon. My name is Roge r 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 ru le 6 and its endeavor to serve the interests of the 7 environment and energy conservation. We do, howeve r, 8 wish to point out certain areas where we believe th e 9 rule as proposed will be counterproductive as it 10 relates to vocational vehicles. 11 Heavy vocational trucks are characterized by n iche 12 applications, low volumes, and special purpose desi gns. 13 Example segments include dump, plows, utility, ref use, 14 fire, and concrete delivery. Within each segment, 15 there are often widely varying vehicle types. Ther e 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 i sHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 167 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 algorithm s 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 t o 11 succeed in the low volume vocational world. The my riad 12 range of vocations lead to a corresponding myriad o f 13 duty cycles, engine and transmission makes, models, and 14 power ratings. Creating specialized engine and 15 transmission integration algorithms takes time, mon ey, 16 testing effort, and a market driver. Engine and 17 transmission suppliers will have little interest in 18 creating the literally hundreds of optimizations ne eded 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 sixbyHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 168 1 two on road tandem. This checkbox will not work fo r 2 most vocational trucks that spend part of their lif e in 3 off road environments, such as job sites, landfills , 4 power line paths, et cetera. 5 Checkbox three is smart stop technology. Shut ting 6 off the engine at every stop will not be practical for 7 fire apparatus where every second counts on the wayto 8 the emergency. Shutting off a mixer engine will st op 9 the drum from rotating and risk the concrete settin g up 10 in the drum. Refuse trucks need engine running whe n 11 they stop to operate collection and packing equipme nt. 12 Checkbox four, neutral idle technology. This 13 approach shifts the transmission to neutral wheneve r 14 the engine is at idle. Certain vocational trucks s pend 15 a lot of time at idle, but the transmission is alre ady 16 in neutral, and the engine power is performing workat 17 that time. 18 Checkboxes five and six involve further 19 improvements to tire rolling resistance. Phase 1 i s 20 already mandating improvements, and we believe thatby 21 2017, further rolling resistance improvements will not 22 be possible without degrading the traction capabili tiesHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 169 1 that most vocational trucks require. Even if rolli ng 2 resistance could be reduced without sacrificing 3 traction, the proposal correctly points out that th e 4 tire manufacturers have little incentive to put 5 research into those tire sizes appropriate, only fo r 6 low volume vocational applications. 7 The seventh and last checkbox involves weight 8 reduction. For applications like concrete or refus e, 9 less weight is already a huge market driver. The p lan 10 suggests a switch to aluminum rims as a most likely 11 possibility, but front discharge concrete mixers an d 12 fire apparatus already use 100 percent aluminum rim s. 13 Another suggestion involves redesigning struct ural 14 components using higher strength steel, but the 15 inherent thinner material are more rapidly degradedby 16 corrosion and exacerbate a major problem in the 17 trucking industry already caused by the increased u se 18 of liquid de-icing agents. 19 The Phase 2 proposal requires that vocational 20 vehicle manufacturers check these boxes on the seve n 21 technologies in order to show compliance. As we ca n 22 see, these boxes either can't be checked, or if the yHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 170 1 are checked, doing so will not result in actual rea l 2 world improvements. Besides being ineffectual, the 3 checkbox approach creates an unfair hardship for th ose 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 on ly 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 acknowle dge 14 the fact that the laws of physics simply do not all ow 15 heavy vocational work trucks the same potential forCO2 16 and fuel economy improvements as is possible for th e 17 higher speed line haul application. Slower speeds, low 18 volumes, off road operation, complex duty cycles, l ack 19 of engine and transmission supplier market drivers, and 20 the nature of the work being performed all work aga inst 21 the vocational product. 22 The Phase 2 regulations should, therefore,Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 171 1 continue the current Phase 1 tire regulations as is and 2 limit further mandates to whatever can be gleaned f rom 3 the engine improvements alone. Thank you. 4 MR. GRUNDLER: Thank you very much. Mr. Queal y, 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. AndI'm 13 here today to urge the EPA and Department of Treasu ry 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 o f my 19 life in a small home in Lansing located on Intersta te 20 294, and I remember clearly on summer days like today 21 going out to play with my friends in the neighborho od, 22 and clearly seeing a visible cloud of exhaust hover ingHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 172 1 over the expressway, and sometimes even creeping as far 2 as my own backyard. 3 Now, the seemingly endless sign of trucks fill ed 4 the expressway as the strong stench of burning fuel 5 invaded the neighborhood. And looking back at my o wn 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 circumsta nces 9 and conditions that I went through when I was young er. 10 Luckily, I do not have any asthmatic conditions, b ut 11 as you can hear from the people who were testifying 12 earlier, it is a very common problem, especially inthe 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 t o 18 support a cleaner planet with more resource conscio us 19 decisions. However, I do believe that significant 20 progress will not be made in a timely manner if theEPA 21 does not implement a full-fledged attack on carbon 22 pollution released by the truck fleets that fill ou rHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 173 1 Nation's roadways. 2 The technology to further improve freight truc k 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 t hat 7 manufacturers connect in conjunction with the EPA i n 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 definitel y an 17 integral facet of our Nation's transportation secto r 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 o f 21 the industry is absolutely heavily beneficial to ou r 22 Nation, but when additional advancements are withintheHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 174 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 by40 5 percent by the year 2025 should be a top priority o f 6 the Agency. Thank you again for your time and allo wing 7 me to testify today. 8 MR. GRUNDLER: Thank you. Thank you for makin g 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 Truc k 12 Trailer Manufacturers Association, or TTMA. I'll b e 13 addressing only the trailer specific portions of th is 14 proposed rule. 15 TTMA is an international trade association of 16 heavy duty trailer builders with members across Nor th 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 appreciati on 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 natu reHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 175 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 take65 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 almos t 7 exclusively for particular customer orders and to t hose 8 customers' particular needs. The trailers can be quite 9 specialized to meet those needs, so variation is th e 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 thei r 15 costs, they will pursue that tenaciously. We see t his 16 is as our customers explore various technologies to 17 maximize fuel efficiency, and thereby reduce greenh ouse 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 workHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 176 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 g as 5 savings, you saw devices being fitted to check off a 6 box. People who would see no gains from the techno logy 7 would have to adopt it, or worse yet, freight wouldbe 8 diverted to exempt classes of trailers, such as 53- foot 9 containers on the chassis, both of which actually s erve 10 to increase fuel consumption and greenhouse gas 11 emissions. 12 We have significant concerns about this propos al. 13 Foremost is that this proposal could essentially 14 become the California mistake writ large, that user s 15 would be required to fit devices to trailers or alt er 16 their basic trailer choices in a way that would not 17 only be costly and inefficient, but would ultimatel y 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 alr eadyHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 177 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 autho rity 8 to regulate our products at all. We also have issu es 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 h as a 18 long history of working closely with regulators to help 19 craft sensible regulations that serve both the indu stry 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 nee dsHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 178 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 th e 4 proposed regulation was crafted over the course of some 5 16 months, our members have been given just a bit o ver 6 60 days to respond. 7 Just understanding what it means to have our 8 products come under EPA rules is a daunting task th at 9 it is just one of the end written consequences of t his 10 proposal, in addition to the requirements in the 62 9 11 pages of the printed document. We lack the dedicat ed 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 submi tted 16 a petition to the docket to extend the comment peri od 17 by at least 90 days, and 180 days would be preferab le. 18 It is still far less than the 500 days or so that the 19 government spent writing it, and it could be of gre at 20 help in actually achieving the agencies' goals of 21 reducing fuel consumption and greenhouse gas emissi ons. 22 Thank you for your time and this opportunity t oHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 179 1 speak. I look forward to answering questions today , 2 and will be available in the future if you should h ave 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 anda 7 half years ago I thought I had the most important j ob 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 th at 10 their job in life is to leave the world in better s hape 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 terrif ied 17 thinking, why am I wasting my time teaching kids wh o 18 may not have water in 10 years? 19 The next morning I called human resources abou t 20 early retirement. Later that year, I realized thatI 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 ,Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 180 1 will have safe water. Safe water is not just a pub lic 2 health issue. It's a matter of global security. A ll 3 over African countries are fighting over water. Inthe 4 Middle East, people are fighting over the Tigris, 5 Euphrates, and Jordan Rivers. Even within the Unit ed 6 States, the southwest has agued that Great Lakes wa ter 7 is a national resource, not just water for the eigh t 8 surrounding states. 9 That brings me to the hearing today. I need y our 10 help to protect my kids. Our water supply is being 11 threatened by how we gain access to fuel, then agai n by 12 the burning of those fuels. Drilling, fracking, le aks, 13 explosions, disposal of waste, all pollute our wate r 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 o il 19 use so that we protect the air and water for our ki ds. 20 I'm happy that the Administration is proposing 21 standards to make our trucks more efficient, but wecan 22 do better, and we must. Forty percent reduction byHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 181 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 maximizi ng 5 fuel efficiency which buffers against the unpredict able 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 c ome 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. Res ist 15 the pressure from the oil companies. Help us leavethe 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 t o 22 address you today. I worked for some 30 years in aHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 182 1 major U.S. warehousing and transportation company 2 primarily in the insurance company. I'm well awareof 3 the efficiencies that producing most of our product s in 4 only a few places and using the trucking industry i n 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 a s 11 affected, but I would let you know that in the pastfew 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. Muchof 17 that growth is automobiles, but much of that growthis 18 in trucking. As we speak, multiple-year constructi on 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 beHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 183 1 using these new roads, but the volume of truck traf fic 2 is increasing significantly. 3 Delivery of goods and transport of materials 4 requires trucks, many trucks. New mega stores in t he 5 outer suburbs, increased terminals at O'Hare, delivery 6 routes using perimeter routes around the mega citie s, 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 communiti es 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 willdo 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 inHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 184 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 pe ople 4 in the drugstore purchasing breathing devices and 5 medications. 6 Older schoolteachers tell us that the number o f 7 kids using inhalers has gone up significantly. I h ave 8 an inhaler which I use on days when the atmosphere is 9 polluted. This is too great a price to pay for qui cker 10 trips, quicker deliveries, less frustration in our 11 transportation. We have concerns about the qualityof 12 our air as the number of trucks going through our 13 communities increases. 14 There is a solution. This solution is in fron t 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 corporati ons 18 need to do this. Our children and children's child ren 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 haveHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 185 1 special provisions for emergency vehicles. It does 2 distinguish between line haul vehicles and vocation al 3 vehicles. Is it your testimony that these provisio ns 4 don't go far enough in your opinion? 5 MR. LACKORE: Well, not having gone through th e 6 whole 629 pages. I focused on the vocational secti on, 7 which in my understanding, if you looked at it woul d be 8 tables V17, 18, and 19 that point to the requiremen ts 9 that I talked to in my paper. So those are the one s 10 that I understand vocational vehicles are going to be 11 required to meet, and that was where I came from th at. 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 implementationfor 15 emergency vehicles, but they would still be require d to 16 check the same boxes as in table V19 by 2027, just have 17 more time to implement. And I would suggest that i t 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 mee t 22 these standards. We are showing the way we derivedHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 186 1 them, but there is no design requirement. 2 Manufacturers are free to choose any means within t heir 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, t he 8 biggest place that you can get savings from obvious ly 9 is aerodynamics. None of our vehicles are aerodynamic. 10 You look at a concrete mixer, a garbage truck, a f ire 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 aerodynam ics. 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 standp oint 20 to improve on those -- in those areas. But I don't 21 know how you measure it. I don't how you measure i t, 22 how you do that consistently between manufacturers,Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 187 1 between designs. 2 And one of the struggles is that if you look a t 3 the number of, say, refuse trucks built in a year, 4 there's about 6,000. You divide that by the numberof 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 l ike 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, allof 12 that to carve out little bits of improvement here o r 13 there in vocational truck design where the -- wherethe 14 volumes are so low, that's where I think is one of the 15 -- is one of the real struggles. If we were buildi ng, 16 you know, 100,000 a year, you could put a lot of 17 engineers behind it and maybe do something. But th at'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 wedo 21 see the differences in these categories, and I don' t 22 think we're expecting a lot of aero improvement inHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 188 1 vocational. But let me turn to my other panel memb ers. 2 MS. BRAKORA: I can speak a little bit to the 3 vocational. I think for the emergency vehicles, th ere 4 is -- the proposal does say just to have tire -- lo w 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 comme nt 9 on what an appropriate threshold would be for a sma ll 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, wh ich 13 is employee based, but we're also requesting commen t on 14 whether a volume exemption is appropriate. 15 MR. GRUNDLER: Yeah, that's great. And I wantto 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 marke t 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 moreHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 189 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 say ing 7 there's a 60-day comment period we think is a littl e 8 bit of a misnomer. 9 MR. FREILER: If you check my testimony, I didsay 10 a bit over 60 days. I am aware that there was botha 11 seven-day extension and a pre-publication version. And 12 we appreciate all the information. There was actua lly 13 a great deal of information from the EPA and the An n 14 Arbor branch on the proposals and the thoughts of where 15 this rule was going. Admittedly, you know, we real ly 16 needed to see the details to be able to start formi ng 17 anything on that. 18 But we greatly appreciate the outreach of both 19 Administrations to our group so that we could do th is, 20 and the work of the Small Business Administration. 21 It's all been very helpful, and we hope that you fo und 22 our input helpful.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 190 1 MR. GRUNDLER: Any other questions? 2 MR. LACKORE: Yeah, ditto. We like working wi th 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 go t 6 that. 7 (Laughter.) 8 MS. BRAKORA: John, to your extension request, 9 were you requesting 90 days additional on top of th e 10 60, or 90 days total? 11 MR. FREILER: On top of the 60, and that is wh at 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 s o 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 o ver 22 here on your right-hand side up front, so we wouldHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 191 1 invite the next panel to come down. There have bee n 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, Christophe r 5 Johnson, Bill Mammen, Alexander Barton, John McNico ls, 6 and Terrence Gallagher. 7 Okay. And as we have the current panel in pla ce, 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 o n 11 the proposed standards for the new EPA regulations on 12 medium and heavy duty truck greenhouse gas emission s 13 and fuel efficiency standards. My name is Glenn 14 Kunkel, and I'm a veteran of the United States Mari ne 15 Corps, and a member of Operation Free, a nationwide 16 coalition of thousands of veterans that advocate fo r 17 securing America with clean energy. 18 I applaud the Obama Administration for proposi ng 19 standards that will make our trucks cleaner and mor e 20 efficient. I joined the military because I care de eply 21 about our Nation's security and stability, and I am 22 here today because along with the consensus of seni orHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 192 1 military and national security experts, I believe t hat 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 ste ps 14 in Iraq to conserve and stretch our resources in or der 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 economi c 18 stability is less threatened. 19 By mitigating our consumption of petroleum-bas ed 20 fuels, we also mitigate a number of disruptions to our 21 domestic security and stability, such as the amountof 22 CO2 that is dispersed into the atmosphere and theHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 193 1 resulting disruptions caused by severe weather 2 patterns. Furthermore, reducing fuel consumption w ill 3 also address the challenge of globally capable 4 extremist groups that often profit from petroleum 5 revenues. Most importantly, I believe that a clean er, 6 more sustainable and efficient United States is goi ng 7 to have to be established in order to maintain our 8 current global posture, both in security capabiliti es 9 as well as economic stability. 10 Although trucks are only seven percent of the 11 total number of vehicles on the roads, they consume25 12 percent of the fuel. This marks a significant perc ent 13 of emissions relative to the number of trucks on th e 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 t o 19 defend us. Everything from tanks to fighter jets t o 20 HUMVEES use oil, and delivering it on the battlefie ld 21 is a dangerous job. In Afghanistan, one in every 2 4 22 fuel convoys results in a casualty. Oil trade rout esHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 194 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 truck s 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 upin 7 the hands of hostile countries and extremist fighte rs. 8 There are economic problems with oil, too. Th e 9 global supply cannot keep up with demand. The pric e 10 will keep going up, hitting all of us at the pump. 11 With this rule, vehicle owners will save an averageof 12 $170 billion in fuel costs over the lifetime of the ir 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 mili tary 17 must repurpose funds away from training, maintenanc e, 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 "NationalHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 195 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 se vere 4 weather events destabilize some of the world's most 5 dangerous regions, and this exacerbates existing 6 national security threats by pushing already unstab le 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 like ly 10 to increase as the impacts of climate change become 11 more acute. While these new EPA regulations make g reat 12 strides to mitigate the impacts of carbon and 13 emissions, such as reducing greenhouse gas emission s, 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 nation al 17 security. 18 Analysis shows that with modern engineering 19 capabilities, stronger standards could reduce truck s' 20 fuel use by up to 40 percent by 2025. Continued 21 progress in environmental standards made by the EPAare 22 vital to the well-being of our Nation as well as th eHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 196 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 o ur 5 men and women into harm's way. 6 Once again, I applaud the EPA for their effort s, 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 th e 22 variety of different areas impacting climate change ,Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 197 1 pollution, and so on. And they're going to have ve ry 2 significant benefits to the economy, health, the 3 environment, and help, as my colleague just said, t o 4 reduce our dependency upon fossil fuels. 5 It is particularly important that the U.S. sho ws 6 this kind of leadership as we head towards Paris fo r 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 c lose 17 to expressways. I have a couple of daughters who b oth 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 a nd 22 others who suffer from breathing problems live bett erHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 198 1 and healthier lives. So thank you for that. 2 According to the ICCT, heavy duty trucks in th e 3 U.S. make up only five percent of vehicles on the r oad, 4 but generate more than 30 percent of carbon dioxide 5 emissions. And they're responsible for more than 3 6 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 import ant 9 the changes will be from the Phase 2 rules savings 10 $550,000 barrels of oil a day, 120 million metric t ons 11 of global pollution, the equivalent of all the 12 emissions from U.S. homes for a whole year. So thi s 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 propo sed 18 Phase 2 regulations, fuel usage from heavy duty tru cks 19 is expected to increase and will exceed the levels in 20 2013 for the future, and so, we aren't achieving al l 21 the results we'd like to get. 22 Studies show that the technologies that are ne ededHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 199 1 to achieve a 40 percent reduction in fuel consumpti on 2 can be incorporated in new trucks by 2025 rather th an 3 2027, and those will save an additional 200,000 bar rels 4 of oil a day in 2035, and avoid 40 million metric t ons 5 of global pollution annually as we've heard before, an 6 equivalent to shutting down 12 coal-fired power pla nts. 7 So I think we have to do everything we possibl y 8 can to look and see whether we can accelerate the 9 changes that you have proposed. And from everythin g I 10 can see, the technology necessary to do that is rea dily 11 available and already in use in Europe and elsewher e. 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 do ing 15 their rounds and also school buses sitting outside the 16 schools. And these vehicles spend most of their ti me 17 doing their most productive work -- or some of them 18 anyhow -- sitting idle and doing no miles per gallo n. 19 And I'm concerned, although I haven't read the deta ils 20 in your proposal, that a proposal to improve the 21 emissions by looking at their miles per gallon is n ot 22 going to get the kind of results that we need. We needHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 200 1 to be looking at how we can reduce their consumptio n 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 thatand 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 n ot 11 necessary, can divert that to a smaller motor or dothe 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 p ower 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 forthe 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. T hey 22 are broken up into different use categories, and th eHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 201 1 intent was to recognize things like the amount of i dle 2 time, so there is a low speed segment built into th e 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 Manchest er, 12 Iowa. I'll start out by disclaiming that even thou gh 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 be ing 19 maintaining vigilance to our impact on our environment 20 is a high priority for us. But we believe it shoul d be 21 through voluntary acceptance of proven technology a nd 22 techniques working well -- working with well though tHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 202 1 out regulations that will make a positive impact, a nd 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 en tity 5 that manufacturers custom built-to-order heavy haullow 6 beds, step deck, and flatbed trailer. As such, we do 7 not have a large team of dedicated personnel to rea d, 8 understand, and comment on all aspects of this prop osed 9 regulation, much less just the basic information th at 10 only applies -- only applies to the truck/trailer 11 industry. Basically I am that team. 12 XL Specialized Trailers would like to thank th e 13 regulatory Agencies for working with Truck Trailer 14 Manufacturers Association, TTMA, which XL is a memb er 15 of, over the past year and a half during the agenci es' 16 initial consideration of this proposal. It's appar ent 17 that some of our fingerprints are found within this 18 document. 19 However, this proposed rulemaking is exception ally 20 involved for our industry, and to help ensure the b est 21 opportunity for comments and assist in the craftingof 22 the proposed regulation, XL Specialized Trailers isHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 203 1 officially requesting a 90-day minimum, ideally six

2 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 trailer s 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 presen ted, 15 a very small list of exclusions and less stringent 16 standards are laid out. We appreciate the regulato ry 17 agencies' proposal allowing of this list, but we as k 18 the agencies to also consider a much broader breakdown 19 to a specific characteristic of what defines a heav y 20 haul trailer. Most of these trailers are not inten ded 21 nor are they used for over the highway long haul 22 operations or at highway speeds for extended period s ofHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 204 1 time. 2 These trailers will operate both on and off ro ad 3 at various speeds and in various terrains. There i s 4 not specific design characteristics that indicate t hat 5 this trailer should operate at low speeds on a spec ific 6 type of train, but there are physical characteristi cs 7 that can distinguish heavy haul style trailers from 8 other trailer types. 9 Heavy haul style trailers are designed to carr y 10 equipment used for construction, agriculture, minin g, 11 logging, power generation, and other industries, 12 specialized loads generally not transported on a 13 regular basis, high center gravity loads, and overs ized 14 length, width, height, and/or weight loads. Genera lly 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 a re 20 owner operated where requirements for specific 21 mandatory design standards for tires and specialty 22 equipment types would cause a larger financial burdenHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 205 1 than the perceived benefit of reduced fuel use. Th is 2 definition list will be submitted as a written comment, 3 and we are asking the agencies to seriously conside r 4 this while developing the language for this regulat ion. 5 As a small business entity, XL Specialized 6 Trailers must consider the potential burden imposedon 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 equipme nt 11 requirements, compliance submissions and record 12 keeping, will create additional burdens to an alrea dy 13 cost sensitive industry. As the proposed regulatio ns 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 standar ds 18 that enhances the efficient operation of our equipment 19 as well as leading to a safer product. Mandating t he 20 implementations of this type of regulation across t he 21 board creates a counter productive environment that 22 leads to subpar products that end up costing consumersHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 206 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 proc ess. 6 Thank you for your time and the opportunity to spe ak 7 during this public hearing. I am able to take 8 questions you may have now, and will be available f or 9 questions that you may have in the future. Thanks. 10 MR. TAMM: Okay. Thank you very much. Mr. Co hn? 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 kno wn 16 as ATIS. My interest in presenting at this hearingis 17 to address the definition of an automatic tire 18 inflation system and the requirements of a "qualifi ed 19 ATIS system." 20 Our company invented our automatic tire inflat ion 21 system 22 years ago and market it globally. In Nor th 22 America, we market it under the Meritor brand name, theHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 207 1 Meritor Tire Inflation System by PSI. Commercial 2 trailer tires receive the least amount of maintenan ce 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 bei ng 7 ATIS. We also estimate that over one million trail ers 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 road side 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 t he 15 tire manufacturers. A typical return on investmentis 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 numero us 20 tire solutions in the market today, and there are 21 operational characteristics between some of those t hat 22 classify themselves under the ATIS heading. With mostHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 208 1 ATIS systems, air is automatically added whenever a n 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 Technolo gy 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 pres sure 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 propose d 21 rulemaking states, and, again, I quote, "ATIS means a 22 system installed on a vehicle to keep each tireHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 209 1 inflated to within 10 percent of the target value w ith 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 perce nt 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 specif ied 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 ti re 12 under inflation. ATIS systems assure that tires wi ll 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 automa tic 20 tire inflation systems are required on non-box trai lers 21 effective model year 2018. It is our recommendatio n 22 that the term "qualified" be expanded.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 210 1 SAE Recommended Practice J2848-2, dated June 2 011, 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 ti re 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 a ny 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 Owne r15 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 drivin g 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 aHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 211 1 single person. 2 So until a year ago, I was an owner-operator j ust 3 like the members I now represent. And I have a fee ling 4 I'm probably the only person here who has actually 5 purchased and driven one of these trucks you're tal king 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 t ruly 15 a make it or break it type of a proposition. You c an 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 ther e 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 seenHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 212 1 from the agencies, and particularly I give a nod toEPA 2 on this with listening to our perspective, listenin g to 3 our membership, and I think also, as we've heard to day, 4 listening to the industry in the broadest sense 5 possible. And while we do feel that the experienceof 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 t hat 10 are going to be regulated, we need to make sure tha t 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 rulemakin g 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 t he 22 OEMs to develop the technologies that will be requi redHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 213 1 in order to maximize the reliability and keep the c osts 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 enti cing 5 with their promised benefits to the environment, th ere 6 are serious concerns about the feasibility of short er 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 emissi ons 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 a nd 16 has included people who have been completely drivenout 17 of business because of the fact of no fault of thei r 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, bu t 21 cost is a special focus for small businesses. Thos e 22 people have already seen the price of a new truck r iseHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 214 1 by tens of thousands of dollars due to the existing 2 regulations on emissions and from Phase 1. No matt er 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 vehicl e. 6 OOIDA has seen that because we do survey our member s 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 perc ent, 11 and that is what has resulted from this issue. 12 So both issues -- the reliability and the pric e -- 13 have the potential to wipe out the promised benefit s of 14 this rulemaking. Keeping the level of stringency 15 attainable is crucial. Political appearances of be ing 16 tough about greenhouse gas emissions certainly can 17 sound good; however, the only way to actually get r eal 18 world results to benefit generations to come is thr ough 19 a rulemaking which leads to vehicles that truckers want 20 to purchase and, and really important here, and the y 21 can afford to purchase. 22 We urge the agencies to continue to hear theHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 215 1 concerns of small business truckers and to incorpor ate 2 these concerns into the rulemaking. With that in m ind, 3 and you've heard this already several times today, we 4 urge the agencies to extend the comment period by a n 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 memb ers 10 want to drive fuel efficient and reliable trucks th at 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 Kev in 17 Brubaker. I'm the deputy director of the Environme ntal 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-base d 22 not-for-profit organization dedicated to the princi pleHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 216 1 that environmental protection and economic growth a re 2 mutually compatible goals. 3 The proposed regulations for heavy truck vehic ular 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 trucker s' 7 wallets. These benefits are particularly important 8 here in Chicago, the center of America's transporta tion 9 networks. Between a quarter and a third of all fre ight 10 movements in the United States come through Chicago . 11 Two-thirds of those freight movements occur on truc k, 12 so we have a strong vested interest in this proposa l. 13 We urge the EPA to strengthen and adopt these 14 regulations. 15 In the interest of time, let me make four simp le 16 points. First, these regulations would protect pub lic 17 health and the environment. The proposed regulatio ns 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 livesHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 217 1 each year. 2 Second, because trucks consume so much fuel, t his 3 regulation is cost-effective. Paying a little morenow 4 for a more fuel efficient truck will result in huge 5 savings at the pump. In fact, tractor trailer owne rs 6 can repay their costs and start earning money on th is 7 investment in just two years. Overall, the new 8 regulations are expected to save society $230 billi on 9 over the life of this program. And when truckers a re 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, th e 20 proposal -- the proposed regulation ignores fuel 21 efficiencies that could be achieved through aerodyn amic 22 improvements to trailers. And lastly, theseHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 218 1 regulations should be fully implemented by 2024 rat her 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 H enry 6 Ford's Model T to about 2010, we had essentially tw o 7 kinds of engines: gasoline and diesel. Today we'r e 8 seeing an explosion of innovation with hybrid elect ric, 9 fully electric, hydrogen, compressed natural gas, a nd 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 th ese 13 changes until at least 2030. Faster implementationof 14 today's rule means flexibility to respond sooner to 15 tomorrow's opportunities. 16 Fourth and finally, the proposed regulation sh ould 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'reso 20 concerned that the proposed rule would actually 21 increase particulate pollution by encouraging the u se 22 of auxiliary power units on trucks. We urge you toHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 219 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 bette r 9 cars that save money at the pump. It's time for 10 truckers to enjoy these benefits as well. Thank yo u. 11 MR. TAMM: Okay. And thank you as well for you r 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 Monr oe 16 Street. We are hopeful, however, that at our next 17 hearing in Long Beach that that might be a little b it 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 makeit 21 possible, and appreciate any assistance you can give. 22 MR. GRUNDLER: Okay, thank you.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 220 1 MR. TROWBRIDGE: If I could, Mr. Grenerth, I t hank 2 you also for your testimony. It seems to me a fair ly 3 crucial portion of what you're asking us to conside r 4 here is the question of whether the upfront costs o f 5 these additional technologies are so great that we 6 wouldn't see the benefits that we're seeking becaus e 7 your members wouldn't be able to purchase trucks wi th 8 these technologies. 9 Is it you contention that we're wrong about th e 10 payback periods for some of these technologies, or is 11 it that a two-year payback period for a new truck i s 12 too long for your members to be able to really makethe 13 decision to make that purchase based on a two-year 14 payback period? 15 MR. GRENERTH: First, I'll say you're absolute ly 16 correct. Payback is great, but first you have to p ay 17 for it, so to put it real simply. And secondly, th at 18 the area of concern comes primarily from the fact t hat 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 histor y of 22 that unfortunately. And, you know, in this case I feelHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 221 1 like we're a little bit closer to reality perhaps o n 2 that because we know some of these things definitel y do 3 work, you know, as I mentioned. They're already wi dely 4 adopted by many fleets and small business owners. 5 But it's just the combination of making sure t hat 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 t hat 14 has been done in listening to other areas. The 15 maintenance costs, you know, of the technology beca use, 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 kno w. 21 While it's great to know that something is under 22 warranty, if you're not earning any money during th eHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 222 1 time when it's being repaired, and that can take da ys 2 in some cases. Parts right now for many emissions3 related items can take days to arrive, and we've ha d 4 one of our members who -- she was sitting in a hote l 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 comme nts. 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 n eed 15 to adjust them or didn't have them right. 16 MR. GRENERTH: Right. 17 MR. TAMM: Okay. If there are no other questi ons 18 from the panel, thank you very much for your commen ts. 19 And we'll ask the group that's in the staging areato 20 move forward. 21 MR. GRUNDLER: I also want to make an announcement 22 that if you're in the audience and are hoping toHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 223 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. Thankyou 11 for the opportunity to make comments on behalf of t he 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 partners hip 22 of America's largest labor unions and environmentalHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 224 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 powerfu l 5 unified voice calling for good family sustaining jo b, 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 leader ship 11 in building the next generation of clean, globally12 competitive energy and vehicle technology. These n ew 13 standards can provide a critical opportunity to save 14 jobs, further reduce the pollution driving climate and 15 foreign dependence, while enhancing the competitive ness 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 manufacturi ng 22 jobs and building the world-leading technology neededHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 225 1 to achieve deep cuts in carbon pollution and save 2 consumers billions at the pump. Soon to be release d 3 research carried out by several of our partners fin ds 4 that more than 380 plants that are manufacturing fu el 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, secu re 8 and grow jobs, and enhance U.S. competiveness acros s 9 these businesses and technologies in the industry a s a 10 whole. 11 We greatly appreciate the thorough and systema tic 12 process EPA and NHTSA have undertaken in developingthe 13 proposal. It is critical that an effective final r ule 14 works for the environment, for the economy, and forthe 15 thousands of hardworking American men and women in the 16 heavy truck component and related industries. We u rge 17 the agencies to continue their thorough and deliber ate 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 globa lly.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 226 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 clima te 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 th e 9 environment. I've written two books about forests, and 10 I've written numerous articles about the environmen t in 11 the Chicago area. During the summer of 2012, I dida 12 lot of bike riding, and I noticed that I was consta ntly 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 i n 17 suffering from asthma. As the quality of our city' s 18 air has grown progressively worse, in 2014 the Amer ican 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, theHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 227 1 number of trucks that come through Chicago. That i s 2 just no secret at all. We're a transportation cent er. 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 tra ffic 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 th e 10 miles driven in the United States, yet they produce20 11 percent of the transportation related carbon emissi ons. 12 They also account for 20 percent of the oil used b y 13 the U.S. Transportation sector. For these health a nd 14 economic reasons, I applaud the EPA and DOT for 15 proposing to reduce trucks' fuel use and lower thei r 16 carbon emissions. However, like other members of t he 17 Sierra Club, I urge you to reduce new fuel consumpt ion 18 even more by 40 percent by 2025 compared to 2020 19 levels. 20 In 2009, the Department of Energy reported tha t 21 the heavy truck energy has or is developing the 22 technology to meet higher mileage standards byHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 228 1 improving engines, transmissions, and tires and by 2 using more aerodynamic designs. Higher mileage 3 standards for heavy trucks would have enormous bene fits 4 for everyone concerned. We would save 200,000 barr els 5 of oil a day and avoid putting an additional 40 mil lion 6 metric tons of global warming emissions into the 7 atmosphere. This would be the equivalent of shutti ng 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 billi on 13 in health and welfare benefits. Thank you very muc h. 14 MR. GRUNDLER: Thank you very much. Mr. Mamme n, 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 an d 19 heavy duty trucks. 20 Our PHV technology has been deployed across th e 21 country, including right here in Chicago, in variou s 22 vocational truck applications, demonstrating real w orldHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 229 1 fuel and emissions savings today. Odyne applauds t he 2 efforts of the EPA and NHTSA to work with the indus try 3 in ensuring the most fuel efficient technologies ar e 4 developed and deployed to increase fuel efficiency and 5 reduce greenhouse gases in the medium and heavy dut y 6 truck sector. Thank you for the opportunity to spe ak 7 before you here today on the proposed Phase 2 rules . 8 While scenario three, which represents the ful l 9 compliance by 2027 for all truck classes and repres ent 10 a positive guidepost for the industry, Odyne believes 11 that cost-effective technology exists to meet timel ines 12 and technology adoption scenarios laid out in scena rios 13 four and five, including fleet adoption rates of pl ug14 in hybrid technology, a technology Odyne Systems ha s 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 vehi cles 21 deployed with the Odyne hybrid technology, we have seen 22 fuel efficiency improvements of 46 percent in drivi ngHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 230 1 alone, and 64 percent in fuel savings when accounti ng 2 for the average full workday, including driving, 3 idling, and powering PTO takeoff activities. Basedon 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 NO x 7 emissions based on the full workday than non-hybrid 8 medium and heavy duty trucks meeting current standa rds. 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 propositi on 16 for hybrid development in the coming years. 17 Odyne believes hybrids will play a larger rolein 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 recommen d 21 that EPA increase the full compliance fuel efficien cy 22 increases for the vocational sector beyond the 16 t o 20Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 231 1 percent or higher. And Odyne would welcome working 2 with the EPA on establishing specific assumptions a nd 3 targets based on its data from the trucks on the ro ad 4 today with technologies currently under development . 5 Odyne understands that it's difficult to model 6 fuel efficiency improvements for hybrid technologie s 7 within the GEM as hybrid systems interact with the 8 transmission and the engine, the overall drivetrainin 9 addition to auxiliary activities beyond driving not 10 currently well modeled in the GEM. But Odyne stron gly 11 believes that it's important to model the full day 12 vocational vehicle duty cycle, including the drivin g 13 and the idling and stationary operation of the truc k 14 mounted equipment through the power takeoff. Model ing 15 the entire duty cycle would be consistent with effo rts 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 mo de, 20 the EPA could miss out on a significant opportunityto 21 increase full workday fuel efficiency for vocationa l 22 vehicles. The segment of vocational class market u singHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 232 1 power takeoffs is significant. Odyne estimates the re 2 are an approximately 100,000 power takeoffs sold 3 annually for medium and heavy duty trucks, and overa 4 million on the road. In addition to accounting forthe 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 t he 8 EPA on best practices and potential paths for model ing 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 f or 15 technologies to become eligible for off cycle credi ts. 16 In Phase 1, the process was unclear for technologi es 17 to become eligible for these credits, which we beli eve 18 was a major hindrance for the industry to drive the se 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 forHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 233 1 earning off cycle credits for the development of hybrid 2 PTO technologies. 3 Overall, Odyne would, again, like to thank theEPA 4 and NHTSA for its developing these proposed regulat ions 5 in Phase 2. We look forward to working with the EPA 6 and NHTSA team going forward as the rules become fi nal 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 thi s 11 panel. 12 MR. GRUNDLER: Thank you. 13 MR. BARTON: I own a company called Green 14 Transportation Solutions that was born in Cook Coun ty. 15 Still live in Cook County, and I'm a member of the 16 Sierra Club. And my company is committed to the us e 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 ,Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 234 1 but particularly in Illinois, on the steps that the y 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 techniqu es 6 going down to no idling and route management as wel l as 7 how to navigate through some of the Federal and sta te 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 redu ce 16 petroleum consumption, and, thus, greenhouse gas 17 emissions with our clients. I'll tell you about th ose 18 now, and I'll stick to my timeframe as well. 19 The first is to increase the use and availabil ity 20 of biodiesel fuels in trucks. Most trucks only usea 21 blend of five percent when they're capable of using 22 upwards towards 20 percent. So that comes down to theHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 235 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 blen ds 5 will automatically reduce petroleum consumption bec ause 6 you're using five percent, 10 percent, or 20 percen t 7 less petroleum, and also providing rural economic 8 benefits domestically, plus a significant reductionin 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 idl e 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 c an 16 reduce your idle time without a hybrid through 17 management. So that would just come down to enforc ing 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 andHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 236 1 parks, as the parts per million for particulate mat ter 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 f uel 6 efficiency, but for safety. It is one of the simpl est 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 positionto 14 be in to try to please everybody. Not easy. And I ’d 15 respectfully urge you to make the standards stronge r 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 t he 22 opportunity to speak with you today on the criticalHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 237 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 important ly, 4 on behalf of my grandkids and their peers across th e 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 t hat 8 I mean I accepted the call to ministry after I spen t 32 9 years in the chemical industry first as an engineerand 10 ultimately as plant manager of a couple of differen t 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 just ice. 14 Ecological justice is simply defined as every huma n 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 wh ich 19 most of the significant environmental regulations c ame 20 into existence. I have to confess that during thos e 21 times decades ago, as each regulation ruled out, wein 22 industry would scream, and wail, and gnash our teet hHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 238 1 that you're driving us out of business, that the so le 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 respons e to 5 these and other proposed standards that would reduc e 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 wer e 10 doing. We got better at what we were supposed to b e 11 doing all along, which is manufacturing with excell ence 12 in response to the restrictions on what we could pu t 13 into the air, dump into the waters, or bury 14 underground. We had to get better at controlling o ur 15 manufacturing processes and controlling our operati ons. 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 wh o 20 stayed got better at what they do. We still grumbl ed 21 about you guys, but maybe with a touch less animosi ty 22 than at first. I understand that you all face grow ingHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 239 1 criticisms for doing what you're intentionally purp osed 2 to do. I understand that daily you get threatened with 3 budget cuts or get treated to the mindless criticis m of 4 a senator with a snowball saying that the snowball 5 proves that climate change is a hoax, and so is you r 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 attack s 11 from the greed-based special interest groups are pa rt 12 and parcel of what will happen when you're doing yo ur 13 job right. If you're not getting them, you got to 14 question if you're going far enough. That's been t rue 15 for your agency from day one, and it'll continue tobe 16 true as long as there are earth systems that need t o be 17 protected for the benefit of the present and the fu ture 18 generations. 19 You know as well as I do that the current foss il 20 fuel burning path our society is on is incompatible 21 with human civilization. There's no other way to s ay 22 it. The path we're on is incompatible with humanHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 240 1 civilization. The only question is time. If our k ids 2 and our grandkids are to have a future, then ultima tely 3 the majority of the fossil fuels have to stay exact ly 4 where they are right now, deep in the earth, not inthe 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 encourag e 9 you strongly to pay attention to their recommendati on. 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 a re 14 simply a start on a very necessary path to a carbon 15 free future. In truth it's a baby step that's take n 16 too long to come into being. After all, the Supreme 17 Court gave you the authority to regulate carbon bac k in 18 2007. So I would ask you to bring a greater sense of 19 urgency to this very necessary work. I know greate r 20 urgency in your implementation plans will undoubted ly 21 incur greater wrath and increased attacks and threa ts 22 to cut your budget, but being comfortable is not yo urHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 241 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 yo u. 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 he re 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 mater ial 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 r eady 22 mixed concrete. In 2014 alone, the industry produc edHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 242 1 more than 324 million cubic yards of concrete, the vast 2 majority of which being delivered in place using re ady 3 mixed concrete trucks. 4 NRMCA holds a number of poignant concerns with 5 Phase 2, including in part costs, technology relian ce, 6 and mainly truck weight challenges. I'm going to f ocus 7 exclusively on truck weights today. The other issu es 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 axle s 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 ofthe 17 proposal and today, that's the set of trucks I'll f ocus 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 appli ed 22 to ready mixed concrete trucks. Due to the realityofHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 243 1 the necessary configuration of trucks, hauling ready 2 mixed concrete, combined with current regulations f rom 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 mix er 6 truck with the lowest possible weight has existed a s a 7 market force since the inception of truck weight 8 regulations. Manufacturing a lightweight mixer tru ck 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 dut y 13 truck weights in order to make suggestions about ho w 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 install ed 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,Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 244 1 structural designs, and necessary specialized indus try 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 tru cks 11 in many cases with a .002 percent margin of weight 12 threshold, meaning under such weight conditions a t ruck 13 merely getting dirty may put it over the legal weight 14 limits and risk noncompliance. Furthermore, the na ture 15 of hauling and delivering concrete gives way to var ious 16 driving road, weather, and construction site 17 conditions. As well, the differences between urbanand 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 design ed 22 to meet this inevitable rough environment. Such aHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 245 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 P hase 5 1 and Phase 2 for complying with the proposal are 6 already being implemented by the industry, and nume rous 7 other suggestions in Phase 2 are simply not practic al 8 for mixer trucks, such as idling reduction technolo gy, 9 which if used in a concrete truck risks the concret e 10 hardening inside the drum potentially causing thous ands 11 of dollars of repairs or a new drum and/or voided 12 concretes. These realities leave technology that h as 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, ifthe 19 industry is forced to reduce its payload in order t o 20 meet low weight tolerances, the industry will then be 21 forced to be -- to use more trucks making more trip s to 22 deliver the same amount of concrete. More trips mo reHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 246 1 means increased emissions, increased fuel consumpti on, 2 more trucks sitting in traffic, and longer hours fo r 3 industry drivers. 4 The ready mixed concrete industry is asking fo r 5 the opportunity to be compliant with Phase 2 and st ill 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 b e 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 on e 15 comment to Mr. Mammen. If you'd be willing to shar e 16 whatever information you have, test information you 17 have, with respect to the hybrid systems that you a re 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 runni ngHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 247 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 en gine 6 and we can run all of the equipment that's needed t o be 7 run off of the hybrid system. And we can run all o f 8 the extra loads. Sometimes they haul generators. 9 Sometimes they haul additional engines to do additi onal 10 work. Our hybrid system can offset all of that andrun 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 o f 16 information we need to help look at the stringency. 17 MR. MAMMEN: Yes, we can do that, and we can a lso 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 collecte d 21 over the years. 22 MR. GRUNDLER: Great.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 248 1 MR. MAMMEN: So we can bring that to the tableand 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 mentio ned 11 that Odyne systems would be interested in more clea r 12 conditions to be eligible for off cycle credits. Ar e 13 there specific recommendations that you have that w ould 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 weget 21 into the system as a non-OEM or as an intermediate 22 stage type manufacturer of a product.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 249 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 n ot 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 f or 13 medium and heavy duty trucks. Earlier a gentleman said 14 I've never driven a truck, but I am very fond of tr uck 15 drivers. I think they do a lot of good work and ar e 16 very responsible people. I also find it very 17 reassuring to hear all of the questions and specifi c 18 suggestions that the other company owners have prov ided 19 in the hearing today. 20 As stated, as part of your name, your agency i s a 21 vital part of our world with our very complicated 22 environment. I am here for myself and others like meHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 250 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 sai d 4 that the carbon standards are an important part of our 5 welfare. I wanted to put another face to the peopl e 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 Associati on. 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 g roup 21 of cancer survivors in the country. I'm sure that most 22 people in the room either know someone or they are aHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 251 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 t o 5 air and other environmental problems such as air 6 pollution. So as medical science continues to impr ove, 7 more people will survive breast and other types of 8 cancer. I don't have asthma as other people mentio ned, 9 but I was present when my beloved niece had a serio us 10 asthma attack, and I have to say that's one of the most 11 terrifying events I've had, including when I got myown 12 diagnosis. I hope that the fuel efficiency standar ds 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 car eful 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 typeof 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 EnvironmentalHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 252 1 Illinois. Environmental Illinois is a non-profit 2 organization that is dedicated to protecting Illino is' 3 natural resources and landscape. 4 Thank you for the opportunity to testify todayin 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 truc ks 8 cleaner and more efficient for the subsequent years . 9 If finalized as proposed, the standards would cut o ne 10 billion metric tons of global warming emissions ove r 11 the lifetime of the trucks affected by the rule. T hat 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 to xic 15 air pollution from idling trucks and refineries tha t 16 produce fuel resulting in $37 billion in health and 17 welfare benefits, including reductions in mortalityand 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 t oHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 253 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 atte nded 6 Chicago public schools. My playground was surrounded 7 by skyscrapers and numerous vehicles passing by, 8 vehicles whose emissions polluted the air and cover ed 9 the city in a fog. When my family moved to the wes tern 10 suburbs of Chicago, my playground became an open gr ass 11 field with fresh air to breathe. 12 My family moved to the suburbs in part becauseof 13 the health benefits. This should not be the case. All 14 children should experience a childhood where they'r e 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 onl y 19 because they will improve public health, but also 20 because they will significantly cut carbon pollutio n. 21 The impacts of climate change disproportionately ha rm 22 poor communities and communities of color. This ru leHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 254 1 is an important part of the President's Climate Act ion 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 efficie nt, 6 and I urge you to finalize strong standards that re duce 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 Illi nois 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 vehic les 18 will save consumers money. According to the Nation al 19 Resource Defense Council and their partner 20 organizations that have researched these standards, 21 consumers will save more money by the decrease of t he 22 use of oil and the use of efficiency technology.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 255 1 Further, consumers support decreasing emission s. 2 A Consumer Federation of America poll released in May 3 2015 found that a majority of Americans favor requi ring 4 manufacturers to increase the fuel efficiency of he avy 5 duty trucks while less than one-quarter opposed thi s 6 requirement. Consumers' voices should be considere d 7 with these standards. The standards are also impor tant 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 plac e 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 heal th 18 of people of this planet and the ecosystems that ar e 19 going. In order -- having these emission standards , 20 making them strong and effective emissions standard s is 21 one part of the many actions that must be taken in 22 order to have a healthier planet to live on.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 256 1 These standards are also important to me as be ing 2 a millennial. Young people now and in the future w ill 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, impr ove 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 th ese 12 standards. I'm here on behalf of Safety Clean Syst ems, 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 Cryst al 16 Clean of Elgin, Illinois, Vertex Energy of Houston, 17 Texas, Vista Oil of Peachtree, Georgia, and Puralub e 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 standard sHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 257 1 for fuel economy and greenhouse gas reductions for 2 these vehicles look at a wide variety of options, a nd 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 r e8 refining lubricating oil when this oil is supplied as 9 an original factory fill. And further, we would li ke 10 to explore with the agencies how ABT mechanisms canbe 11 used to allow credit for re-refined oil supplied du ring 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 a s 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 redu ces 21 greenhouse gas emissions compared to the use of eng ine 22 oil made from virgin crude. This analysis, conduct edHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 258 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 mil lion 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 burni ng a 11 gallon of diesel fuel. 12 Our published analysis shows that even if we 13 conservatively include other factors, such as emiss ions 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 asHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 259 1 original equipment and as part of maintenance of th e 2 vehicles. Allowing OEMs to receive credit for thes e 3 greenhouse gas savings will provide them with 4 additional flexibility to achieve the targets beingset 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 reduci ng 9 greenhouse gas emissions. 10 When the total life cycle benefits are factore d 11 in, the use of re-refined oil has benefits comparab le 12 to the use of low rolling resistance tires. With t his 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 b e 16 adapted to avoid greenhouse gas emissions with re17 refined oil in original factor fill and service fil l. 18 Credit for future maintenance could be provide d on 19 a tradable basis allowing the manufacturer to buy GHG 20 reduction benefits each time the oil is changed usi ng 21 re-refined oil in the future and maintenance cycles . 22 By allowing future tradable credit, the manufacture rHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 260 1 would be given an incentive to promote the use of r e2 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 comme nts 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 doi ng 10 well today. My name is Hannah Flynn. I am speakin g on 11 behalf of the Sierra Club and testifying as a resident 12 of Hyde Park, Chicago. I'm a fourth year environme ntal 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 fo r 16 fuel efficiency are a meaningful way to arrive at a 17 cleaner, healthier, and more economically robust se t of 18 regulations on heavy duty freight trucks. 19 As a young person, I'm concerned about the fut ure 20 of this planet. It is well understood that the poi nt 21 of carbon -- at this point that carbon pollution, b e it 22 from methane or carbon dioxide, contributes greatlytoHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 261 1 the warming of our atmosphere and the heightening o f 2 climate change. We're already seeing the effects o f 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 Clea n 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 f or 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. Afte r 19 all, some vehicles, such as tractor trailers, have 20 meager fuel efficiency standards, fewer than 10 mil es 21 per gallon, that have not changed in decades. Of 22 course, standards should be tailored to the vehicleHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 262 1 type. 2 Therefore, I urge the EPA to set an even highe r 3 target. It is entirely possible to have a 40 perce nt 4 reduction in trucks' fuel usage by 2025. The 5 technology exists in forms of drag treatment, advan ced 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 driver s. 11 By requiring less fuel to drive, the average big ri g 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 havinga 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, andthe 19 lasting power of carbon dioxide in our atmosphere i s 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 t hatHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 263 1 is just as high quality as today, even if not even more 2 so, an egalitarian planet with clean air and minima l 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 commendthe 8 prior speaker. She took a little bit of my fire, b ut 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 t han 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 operat ed. 22 But they all come under the same rules and regulat ionsHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 264 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 r ule 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 atthe 7 mercy of the truck and trailer manufacturers for ye ars 8 to provide the equipment that is safe, but not alwa ys 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 dri ver 12 who has been trained to shift correctly and to be l ight 13 on the gas pedal to achieve even minimal fuel savin gs. 14 That's hard for a company to handle when their 15 best driver is lucky to get six or six and a half m iles 16 per gallon, and it's even worse for the local short 17 haul drivers. The gentleman who represented the Re ady 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 effor t to 22 incorporate not just better engines, but to encoura geHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 265 1 mechanical and aerodynamic improvements to commerci al 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 l ie 5 ahead to reach the goal of a 40 percent reduction i n 6 fuel consumption in the next 10 years or so. 7 The cost associated with achieving this goal a nd 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 investe d 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 loca l 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 mean ing 21 that an even bigger return on investment may be 22 possible because they do keep that truck maybe up t o 10Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 266 1 years. 2 May we suggest, though, also that other measur es 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 there by 6 reduce congestion, unnecessary emissions due to idl ing 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 t o 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 righ t 13 now if we would encourage more nighttime and weeken d 14 deliveries. 15 This would require the cooperation of shippers , 16 trucker, and government bodies that would encourageoff 17 peak deliveries and maybe encourage a reduction in 18 tolls on the tollway, maybe a change in the hours o f 19 service regulations to encourage truckers to operat e at 20 night. And also it would improve truck access. 21 Midwest Truckers is also involved in projects rightnow 22 with the Illinois Tollway to identify and to develo pHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 267 1 more facilities for truck platooning and parking, t o 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 t his 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 savi ngs 9 for these truck operators. And, of course, then th at's 10 passed onto the consumer, who could benefit from th e 11 fact that lower fuel consumption means less overhea d 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, andHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 268 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 wha t we 4 can to mitigate climate change. That means making vast 5 improvements in transportation, and eventually phas ing 6 out completely fossil fuels and transforming to 7 renewable energy. 8 In that context, I think that I support strong ly 9 the Administration and the EPA for introducing thes e 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 tha t 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, whenI 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 legisla tors 22 in Springfield, and they, therefore, relax theHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 269 1 pollution controls. 2 Because of the climate crisis, we can no longe r 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 f uel 6 as we bring in renewable energy is something we sho uld 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 o ver 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 sav ings 15 would be realized as we bring in this fuel efficien cy 16 and we work in the scientific community concurrentl y to 17 phase in renewable energy, you know, control releas e 18 systems using hydrogen, which is a non-greenhouse g as. 19 Those efforts are under way. But we have time to go, 20 and these fuel efficient standards are going to hel p a 21 lot. 22 So just as a concerned citizen, I want to expr essHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 270 1 my appreciation to the Administration and the EPA f or 2 implementing these new standards. And as a citizen , 3 which I'm mostly here today and also serving on theAir 4 and Energy Committee of the Sierra Club, I just wan ted 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 suppo rt 11 these and work together to achieve a green sustainable 12 economy, and particularly in transportation. So th ank 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, thankyou 21 for preparing and proposing this unified proposal f or 22 the greenhouse gas reductions and fuel reductions.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 271 1 That spurs on the development of advanced technolog y 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 manufactu rer 6 of products for the medium and heavy duty commercia l 7 vehicles, it's noteworthy that it provides these 8 aggressive targets and for improved performance, bu t 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 comment s on 14 proposed test duty cycles and their adequacy. We'r e 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 applicatio n, 21 the maximum impact can be obtained without the sub22 optimization of components' performance, such asHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 272 1 engines, transmissions, structures, and other thing s. 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 tar get 8 improvements, the proposed requirement of 16 percen t 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 greate r 14 percentage should be considered to drive the innova tion 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 cred its 21 for applying energy saving technologies by delegate d 22 final stage manufacturers, such as vocational vehic leHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 273 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 fl ow 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 no t 8 incentivized to take such risks. The cost of bring ing 9 a game changing technology or product to market fac es 10 many obstacles in breaking out of the status quo an d 11 the established market inertia. The lack of adequa te 12 incentives and credits for this taking this path ma kes 13 it less desirable, potentially keeping new technolo gies 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 al so 19 no credits to encourage them. Perhaps you will 20 reconsider adding back in the credits for implement ing 21 advanced technology and find an equitable means of 22 delegated final assembly OEMs to receive or roll upHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 274 1 these credits. Your challenge will be to objective ly 2 new and innovative technologies and method applying 3 these advanced approaches that do not fit the statu s 4 quo. 5 Modifications to measurements and certificatio n 6 methods may be required, and flexibility to adapt t hese 7 processes to accommodate promising and impactful 8 technologies will be crucial. Some of these challe nges 9 include organizational empowerment, policy overhaul , 10 working level encouragement and grace for risk taki ng, 11 and flexible compliance throughout your organizatio ns. 12 We sincerely appreciate the overall body of wo rk 13 that's been poured into this unified proposal, and we 14 appreciate that you are actively seeking stakeholde r 15 input and comment. We hope that in the end the res ult 16 of this groundbreaking policy will have an impact f or 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 s hape 20 the final rule structure. 21 MR. TAMM: Okay. Thank you very much for your 22 comments. Are there any questions from the --Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 275 1 MS. BRAKORA: I just have one comment on the Mr. 2 Nichols -- McNicols. The innovative credits I beli eve 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 sti ll 7 be able to -- a manufacturer still should be able t o do 8 some off cycle credit tests to obtain values for th at. 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 design ated 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 tha nk 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 w ith 21 your Northwestern colleagues, but hopefully before the 22 end of the day --Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 276 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 ver y 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 residentof 16 Chicago. I'm in favor of the second phase of standards 17 that both the Environmental Protection Agency and t he 18 Department of Public Transportation proposed to reduce 19 carbon emissions and oil use from heavy freight tru cks. 20 The main reason I'm in favor of the proposed 21 standards is that I have suffered from severe healt h 22 problems that are exacerbated by pollution. Since IHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 277 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. Durin g 8 that time, I had to avoid Michigan Avenue and other 9 streets that have a lot of traffic from large vehic les. 10 Since the charcoal masks made me unemployable, I c ould 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 tobe 18 hospitalized for a heat emergency, and after that s he 19 could never tolerate heat as well again. My parent s 20 and my best friend are all elderly, and I'm concern ed 21 about the effects the heat will have on their healt h. 22 My best friend can't afford to run her air conditio nerHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 278 1 except in the hottest of weather, so I'm especially 2 concerned about her. 3 Finally, I have noticed that extreme heat in t he 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 o ne 8 so far this year. They were severe emergencies bec ause 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 carb on 12 emissions from 530 million metric tons to 270 milli on 13 metric tons by 2030, and thus decrease global warmi ng. 14 In addition, both phases of standards would reduceoil 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 propo sed 18 standards to reduce oil use and carbon emissions fr om 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 r ightHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 279 1 in and take care of business. I appreciate the 2 opportunity to testify today. My name is Tim Milbu rn. 3 I represent Greenways to Go, a consulting company in 4 Illinois focusing on SmartWay to reduce pollution i n 5 transportation. I am here in strong support of the 6 proposed standards that will make our larger vehicl es 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 polluti on 15 control engineer. I understand and physics of the 16 resulting products of combustion and how they inter act 17 with the environment once they leave the tailpipe. 18 Based on the broad consensus of many experts, I agr ee 19 the time is now to act to reduce the CO2 emissions, 20 else we face increasingly serious challenges relate d to 21 climate change. 22 The transportation and energy sector represent sHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 280 1 about one-third of the total CO2 generated in the U .S. 2 Based on U.S. Energy Information Administration da ta, 3 the targeted larger vehicle group represents about 20 4 percent of the transportation total, second to ligh t 5 duty vehicles at 54 percent. 6 A key role of democratic government is to crea te 7 reachable, practical targets that benefit society a nd 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 applie d 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 sour ces 14 of pollution per mile driven, and a large contribut or 15 to pollution and the associated negative human heal th 16 and environmental impacts. The plan further target s 17 having a two-year payback in fuel savings versus th e 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 AmericanHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 281 1 innovation can provide solutions that benefit socie ty 2 as a whole by continuing to lead the U.S. and the w orld 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, job s, 6 reduced risks, and reduced costs required to global ly 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 c ash 13 flow. Initiatives like the fuel efficiency standar ds 14 help educate all of us on why we should be mindful of 15 proper stewardship of the finite air, water, and la nd 16 resources we share. 17 I urge you to finalize and adopt these or stro nger 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.)Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 282 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 whe n 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 publi c 9 hearing on the EPA/NHTSA heavy duty fuel economy an d 10 greenhouse gas emissions standards. We believe thi s 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 fo r 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 poli cy, 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.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 283 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 becau se 6 it will benefit the economy, particularly the truck ing 7 industry, by spurring innovation in truck design soas 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 overa ll 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 th e 16 Consumer Federation of America, in a poll that foun d 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 fo r me 20 to testify, and I applaud the Administration, the E PA, 21 the DOT, and all the other stakeholders involved wh o 22 helped make these new standards a reality.Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 284 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 busin ess 15 as usual. Bold engineering in efficiency of trucki ng 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 practical ity 20 and their deep commitment to sustainability on eart h. 21 Union of Concerned Scientists, Sierra Club, and Emo ry 22 Levin's book, Reinventing Fire. I'm proud to be aHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 285 1 paying member of the first two groups, and I've enj oyed 2 Reinventing Fire for its very thorough review of ho w to 3 achieve a great economy on much less energy. These 4 groups are well studied and well informed on what i s 5 possible to keep our country great and leadership i n a 6 clean energy economy. 7 Included in my handout, I will have a graph ou t of 8 Reinventing Fire that shows six different areas of 9 redesign of our Class A trucks and how we can achie ve 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 w ill 14 surely be higher than today. From my experience in 15 being in sustainability and a renewable energy advo cate 16 is that energy efficiency is a low hanging fruit wi th 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 perce nt 22 reduction of fuel savings of new trucks by 2025. N ewHearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 286 1 truck higher costs of $32,000 would save $30,000 ina 2 year. That is a win in any business person's book. 3 We should be bold in our moves to be leaders i n 4 the world of engineering, product development, ener gy 5 efficiency, and, therefore, business costs. This k ind 6 of move will benefit our climate, the health of our 7 children, and life on earth. This is the kind of w in 8 where -- that everyone will gain from. 9 Thank you for your time. 10 MR. GRUNDLER: Thank you. Any questions for t his 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 t o 18 provide testimony before we adjourn? 19 (No response.) 20 MR. GRUNDLER: Representative from Caterpillar ? 21 No? 22 MALE SPEAKER: (Off audio.)Hearing August 6, 2015 Chicago, IL

1-800-FOR-DEPO Alderson Reporting Company Page 287 1 MR. GRUNDLER: This concludes our public heari ng. 2 Thank you very much. 3 (Whereupon, at 4:56 p.m., the meeting was 4 concluded.) 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22l"(.ìhiill,:rle\\,illiirrrrs.rt.ll,:r..,ll\,cer'rif'\,thattllcfìrrcgoittuisatt'itc"¡'¡¿lç;¡¡¡¡¡'ert:tt¡.ltüsr-rr.i¡rt.r,r,iihtlrrtlrltct':ltii-rtrs,l''t'tllllthc:clcc:tl-'ltricsotllli[t'cctllrlirlgoritlitrlilt'tll¿tlttllt['tt¡tLt.t,,xIi\\jIl.l-l;\N'[soNt'lìANs('ll.ItJlil{