General Motors 

Testimony regarding 

Heavy-Duty Phase 2 CAFE/GHG Rule 

Docket ID: EPA-HQ-OAR-2014-0827 

Given by: Barbara Kiss 

Long Beach, CA 

Tuesday, August 18, 2015 

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Good morning. My name is Barbara Kiss and 1 am the Director of Environment and 

Energy Policy at General Motors. 

I am pleased to speak with you today regarding the EPA and NHTSA Notice of Proposed 

Rulemaking to address greenhouse gas and fuel efficiency for medium and heavy-duty 

trucks. 

General Motors is a major manufacturer of these vehicles, and we want to thank NHTSA 

and EPA for providing the opportunity to comment on this regulation. We have been 

working closely with both agencies, and will continue to do so in order to establish 

standards for this integral part of the American economy. GM supports the adoption of a 

national standard covering these vehicles, and it is paramount that it be consistent with 

some critical and foundational principles: 

First, it is imperative for NHTSA and EPA to develop a harmoni zed approach that does 

not penali ze both consumers and manufacturers in providing products that continue to 

serve the purposes, functions and utility that are needed. General Motors is supportive of 

the approach used during Phase 1 of this initiative, and encourages the continued 

harmonization of CAFE and GHG regulations. By creating one national standard, we can 

best maximize resources to produce clean and efficient vehicles which better align with 

the emission reduction standards put in place. 

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Second, the program must continue to recogni ze the unique functionality and utility 

needs of the trucking industry, and that we provide vehicles that preserve the 

performance integrity of these work trucks. Consumers value the payload and towing 

capabilities these working vehicles offer, and the "work factor based" standards set by 

EPA and NHTSA should continue to align with the industry and business needs of this 

demographic. 

Third, we have been gaining valuable experience concerning the importance of realworld flexibility mechanisms contained in the light duty vehicle greenhouse gas and fuel 

economy regulations - and these lessons can be applied to the medium and heavy duty 

fleets. These mechanisms include recognition for technologies that reduce fuel usage in 

conditions not comprehended in the standard fuel economy tests, such as colder weather, 

higher speeds, or extended idle times. GM intends to provide detailed written comments 

and data that support inclusion of similar mechanisms for the heavy duty regulation. 

We have also had favorable experience with the extended caiTy-forward time allowed in 

the light duty regulation, which has resulted in GM achieving fuel efficiency 

improvements sooner than required, thereby providing us with greater latitude to manage 

our product cadence in very competitive market segments. This concept could also be 

applied to the medium and heavy duty segments. 

The agencies' proposed Class 2b/3 standards based on alternative 3 in the Notice of 

Proposed Rulemaking will continue to drive innovation and cause GM to invest in and 

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refine new technologies that are both appreciated and optimized by American consumers. 

This path will challenge our product plan and drive considerable technology into our 

heavy-duty trucks and vans. While we are cautiously supportive of this path for future 

emission reduction standards, it's important to note that Alternative 3 increases the 

effective stringency far beyond what a cursory analysis of2.5% per year would suggest. 

The combination of procedural, modeling and fuel changes results in a more stringent 

regulation. GM intends to discuss these in detail as part of our written comments. 

Finally, the program must attempt to minimize the potential for unintended 

consequences, especially for the consumer. The heavy duty fleet does not benefit from 

the years of data that have been collected and analyzed for the light duty fleet. Further, 

the utility provided and the duty cycle of these vehicles is completely di ffc rcnt from the 

light duty fleet, and any attempt to force more stringent regulations, such as Alternative 

4, would be extremely detrimental to manufacturers, consumers, the U.S. economy and 

the mi II ions of transportation-related jobs. 

Indeed, comprehensive data for this product segment is only now being accumulated and 

analyzed for the 20 14 model year, which is the first year of Phase I of the medium and 

heavy duty truck regulations. This new data should be carefully evaluated by the 

technical experts at the Agencies and compared to the estimates and assumptions that 

formed the basis for both Phase l and the proposed Phase 2 of these heavy duty 

regulations. 

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As mentioned, we will be providing more extensive written comments to address the 

breadth of issues associated with the continued expansion of this program. We look 

forward to working with NHTSA and EPA to assure that the program created is national 

in scope and consistent with these principles. Thank you. 

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