STATEMENT OF THE 

MANUFACTURERS OF EMISSION CONTROLS ASSO.CIATION 

ON THE ENVIRONMENTAL PROTECTION AGENCY'S PROPOSAL: 

GREENHOUSE GAS EMISSIONS STANDARDS AND FUEL EFFICIENCY 

STANDARDS FOR MEDIUM- AND HEAVY -DUTY ENGINES AND VEHICLESPHASE2 

August 6, 2015 

My name is Dr. Joseph Kubsh. I am the Executive Director of the Manufacturers of 

Emission Controls Association, or MECA. MECA is pleased to provide comments in support of 

the U.S. EPA's proposed rulemaking to establish medium- and heavy-duty greenhouse gas 

emission standards and corporate average fuel economy standards for model years 2018 and 

beyond. We believe an important opportunity exists to continue to reduce greenhouse gas 

emissions and improve fuel economy from medium- and heavy-duty engines and vehicles by 

applying the fundamenta l regulatory structure that has been effective under the first phase of the 

medium and heavy-duty standards. 

MECA is a non-profit association of the world's leading manufacture rs of emission 

control teclmology for mobile sources. Our members have over 40 years of experience and a 

proven track record in developing and manufacturing emission control and e ffi ciency technology 

for a wide variety of on-road and off-road gasoline and diesel fueled vehicles and equipment in 

all world markets. Now that regulated pollutants have been expanded to include C02, the 

portfolio of products offered by our members has expanded to technologies that impact 

combustion efficiency and improve the overall C02 emissions of the powertrain. These 

technologies include waste heat recovery, turbochargers, turbo-compounding, EGR coolers, 

EGR valves and other air management technologies, thermal management strategies including 

insulated dual wall manifolds and exhaust systems, active thermal management approaches, 

advanced fuel injection and ignition systems. The mobile source emissions control industry has 

generated hundreds of billions of dollars in U.S. economic activity since 1975 and supports more 

than 65,000 U.S. jobs, mostly in product development and manufacturing. EPA's proposed 

Phase 2 emissions and e fficiency standards will provide additional support for the continued 

development of a thriving U.S. industry focused on a wide range of technologies that can reduce 

vehi cle emissions and improve fuel efficiency. 

MECA would like to offer the following comments on specific aspects of EPA's Phase 2 

proposal: 

1. MECA strongly supports the continued use of separate engine and vehicle standards 

included by EPA in their Phase 2 proposal. This fran1ework developed for the Phase 

1 heavy-duty standards ensures the continued important testing linkage between 

engine criteria and greenhouse gas emissions, and ensures that manufacturers deliver 

durable, enforceable improvements to truck fuel efficiency. 

2. MECA believes that cost effecti ve technical solutions will be available to allow for 

the faster 2024 implementation time line included in EPA's proposa l. Manufacturers 
need this regulatory clarity to continue to make needed investments on technologies 

that will deliver these reductions. 

3. MECA supports EPA's proposal to lower the cap on N20 emissions from 100 to 50 

mglbhp-hr. This tighter N20 cap will be challenging in the expected future of lower 

exhaust temperatures associate with improved engine efficiencies but manufacturers 

have a number of technical opportunities available to them to keep N20 emissions at 

low levels, including improved catalyst formu lations, ammonia slip catalysts with 

high selectivity for nitrogen formation, and efficient urea dosing strategies. 

4. MECA supports EPA's proposal to c lose the current emissions loophole on truck 

glider kits. The legacy of dirty diesel engines on America's roads needs to put in our 

rear view mirror. All new trucks need to utilize the clean diesel engine options that 

have been available since 20 10. MECA asks EPA to consider an earlier closing of 

the glider truck loophole instead of waiting until 20 18 to get these dirty diesel options 

off the table. 

5. MECA believes that future auxiliary power unit PM emissions should be controlled 

through the application of proven diesel particulate filter technology to these small 

off-road engines. There are already examples of small off-road di esel engines 

engineered with filter solutions that include active regeneration. EPA should follow 

California's lead and implement policies for APU engines that force the application 

of cost effective filter solutions on these engines. 

Finally, MECA believes that significant further reductions in NOx emissions from nevv 

heavy-duty on-road diesel engines beyond the 2010 highway requirements will be possible 

through the combinations of more advanced diesel engines with evolutionary improvements to 

the growing suite of advanced diesel exhaust emission control technologies including high cell 

density, low thermal mass substrates, improved SCR catalyst systems coated directly on filter 

substrates, and advanced oxidation catalysts that include passive NOx absorber capabilities. 

Clean diesel emission technologies have expanded and matured considerably since EPA 

finalized their heavy-duty 2007-2010 emission standards nearl y 15 years ago in late 2000. The 

application of SCR technology on diesel engines has allowed engine manufacturers to optimize 

diesel engines for both low NOx emissions and improved fuel efficiency and we believe that 

these optimizations can continue in the future to allow diesel engines to further reduce both C02 

and NOx emissions. Advanced diesel emission control technologies are currently being 

evaluated in a California-sponsored test program to demonstrate the capabilities to meet a 0.02 

glbhp-hr NOx standard without negatively impacting C0 2 emissions. Results from this test 

program are expected before the end of next year. The emission reduction benefits achieved 

through the deployment of advanced diesel emission control technologi es are focused on 

de livering NOx reductions during the cold transient portion of the test cycle and to improving 

NOx emissions performance in low temperature duty-cycle operations. Additional NOx 

reductions from heavy-duty engines will provide important cost-effective reductions for regions 

of the country with cuiTent and future ozone non-attainment issues. MECA asks EPA to initiate 

a rulemaking that will further reduce NOx emissions from heavy-duty engines as soon as 

possible to allow manufacturers to work with their customers on delivering fu ll y optimized 

future engines that deliver improved fue l e ffic iency and ultra-low NOx emissions. 

CONTACT: Joseph Kubsh. Executive Director MECA, E-mail: jkubsh(@.meca.on! 

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