# TESTIMONYOF: Cynthia Williams

Associate Director Vehicle Environmental Regulatory Strategy & 

## Planning Ford Motor Company



# EPA andNHTSA Public Hearing "Phase 2 Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles"**Tuesda~August1~** 

## 2015Good morning, I'm Cynthia Williams, Vehicle Environmental Regulatory Strategy & Planning Associate Directorfor Ford Motor Company. It is a pleasure to be here today to provide the Ford perspective on this very important rulemaking. We commend the efforts of EPA and NHTSA in the difficult task of developing this second phase oftheir greenhouse gas emissions and fuel efficiency standards for medium and heavy-duty engines and vehicles. Moreover,we commend the agencies for working closely with the California Air Resources Board in developing these proposed standards. We are committed to working with EPA, NHTSA and ARB to finalize these regulations as a single national program that would allow manufacturers to continue to build a single fleet ofvehicles and engines.
Before I talk about the proposed rulemaking , I would like to spend a moment telling you about the progress that Ford is making in executing our long term sustainability plan. In addition our recent introduction of our line offuel efficient full-sized vans called 'Transit", Ford is investing billions ofdollars overthe next five years to introduce technologies that improve fuel economy and reduce the greenhouse gas emissions ofourfleet. We're driving innovation in every part of our business to deliver advanced new products and to change the way the world moves. Commercial truck customers demand technologies that provide "value for money" while providing truck functionality, whetherit's volume for people or cargo, the ability to haul large loads, or to work off-road. Fuel economy continues to be very important to our commercial truck customers, and Ford has invested in technologies to maintain customer satisfaction. You will continue to see us offer more great products with advanced, innovative technologies to improve the fuel efficiency ofour vehicles and to deliver outstanding quality and features that our customers desire. Ford's complete and incomplete vehicles in this segment consist ofTransit and Econoline vans, F-Super Duty trucks and motor homes.

Page 2 of4 August 17, 2015Turning now to the proposed rulemaking, Ford supports the continuation ofthe harmonized greenhouse gas emissions and fuel consumption regulatory framework for over 8500 pound vehicles. The Phase 

### 2 proposal offers challenging greenhouse gas and fuel economy targets, particularly in the context of new emissions standards and changes to test fuel properties in the same time period. These external factors increase the effective stringency and technology forcing aspects ofthe Heavy Duty Greenhouse Gas·proposal beyond what the numerical value of the standards alone would suggest. In fact, Ford projects that many ofthe technologies assumed not to be required until the final 2027 standards are present and will likely have to be included in the 2024 time-frame simply to make up for these external factors.
As mentioned earlier, we offer essentially two types of complete vehicles: a van and a pickup truck. With limited opportunities to implement significant product actions, it becomes critically important to provide manufacturers with adequate lead-time to meet these requirements. As with Phase 1 , the proposal includes a range of compliance mechanisms such as the ability to carry forward credits from prior model years as well as vocational vehicle and engine averaging, banking and trading provisions. Ford supports expansion ofthe Phase 1 allowances to generate emission credits for 

### C02improvements for technologies providing on-road fuel consumption benefits that are not captured by the emissions test cycles or models. Ford supports the establishment ofstandards that: • Recognize the needs ofthe trucking industry and other commercial users • Increase the use of known technology found to be feasible and effective in this market segment • Preserve the utility and functionality ofthese commercial vehicles including maintaining separate gasoline and diesel targets • Are compatible with the complexities of the marketplace; and

Page 3 of4 August 17, 2015• Avoid unintended consequences.
Ford agrees with the revised EPA and NHTSA approach that uses a more sophisticated Greenhouse Gas Emissions Model to drive both powertrain and chassis improvements. That being said, Ford has some concerns with the accuracy of the model for Vocational Vehicles, particularly in the case ofvehicles with Heavy Duty Gasoline and Light Heavy Duty Diesel engines. Ford recommends that data is used to validate the model and intended duty cycle definitions for these engine-vehicle combinations. Ford will provide detailed written comments on this subject once we have fully evaluated the model and will continue to cooperate with EPA and NHTSA requests for data to support the refinement of the GEM model. Finally. Ford recognizes the benefits for the country ofcontinuing a uniform National Program to address greenhouse gases and fuel efficiency from medium and heavy-dutyvehicles. The EPA and NHTSA Phase 1 proposal was the first step to providing the clarity, certainty and flexibility necessary to achieve the aggressive greenhouse gas emissions reduction goals that we all share. The proposed Phase 2 builds and expands on this progress, setting challenging targets for industry for the next decade. Once again, Ford appreciates the opportunity to provide our testimony on this important rulemaking. We are continuing to review all of the technical aspects ofthe proposal and we plan to provide detailed written comments aimed at achieving and finalizing regulations consistent with the commitment that all parties have made to this national program.
Thank you and I will be glad to take any questions.

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### August17, 2015