TESTIMONY OF: 

Cynthia Williams 

Associate Director 

Vehicle Environmental Regulatory Strategy & Planning 

Ford Motor Company 

EPA and NHTSA Public Hearing 

"Phase 2 Greenhouse Gas Emissions Standards and 

Fuel Efficiency Standards for Medium- and Heavy-Duty 

Engines and Vehicles" 

Tuesda~August1~ 2015 
Good morning, I'm Cynthia Williams, Vehicle Environmental Regulatory Strategy & Planning 

Associate Director for 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 of their 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 of vehicles 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 of fuel efficient full-sized vans called 'Transit", Ford 

is investing billions of dollars over the next five years to introduce technologies that improve fuel 

economy and reduce the greenhouse gas emissions of our fleet. 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, whether it'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 of our vehicles and to deliver outstanding quality and features that our 

customers desire. Ford's complete and incomplete vehicles in this segment consist of Transit 

and Econoline vans, F-Super Duty trucks and motor homes. 

Page 2 of 4 August 17, 2015 
Turning now to the proposed rulemaking, Ford supports the continuation of the 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 of the Heavy Duty Greenhouse Gas· proposal beyond what the numerical value 

of the standards alone would suggest. In fact, Ford projects that many of the 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 of the Phase 1 allowances to 

generate emission credits for C02 improvements for technologies providing on-road fuel 

consumption benefits that are not captured by the emissions test cycles or models. Ford 

supports the establishment of standards that: 

• Recognize the needs of the 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 of these commercial vehicles including maintaining 

separate gasoline and diesel targets 

• Are compatible with the complexities of the marketplace; and 

Page 3 of 4 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 of vehicles 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 of continuing a uniform National Program to 

address greenhouse gases and fuel efficiency from medium and heavy-duty vehicles. 

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 of the 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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