NAFA 

Fleet Management Assodation 

STATEMENT OF 

CHRIS WILLIAMS 

NAFA FLEET MANAGEMENT ASSOCIATION 

BEFORE THE NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 

AND THE 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

LONG BEACH, CALIFORNIA 

AUGUST 18, 2015 

Thank you ve ry much for providing this opportunity to speak today on the Phase 2 

Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and 

Heavy-Duty Engines and Vehicles. 

I am Chris Williams and here today day on behalf of professional fleet managers and 

NAFA Fleet Management Association. I am a NAFA member and the Fleet Manager for 

Gothi c Landscape, where I am responsible for vehicles in California, Arizona and Nevada. 

Previously, for 30 years I was the Fleet Manager for Verizon with responsibility for vehicles 

in the California, Texas and Florida. 

NAFA's members are responsible for the majority of class 3 to 7 trucks in fleets in 

the United States and Canada. NAFA is the association for professionals who manage fleets 

of sedans, public safety vehicles, trucks, and buses of all types and sizes, and a wide range 

of military and off-road equipment. NAFA's members are responsible for the specification, 

125 Village Boulevard, Suite 200 • Princeton Forrestal Village • Princeton, NJ 08540 

Tel: (609) 720-0882 • Fax: (609) 452-8004 • www.nafa.org 
acquisition, maintenance, repair, fueling, risk management, and remarketing of more than 

4.6 million vehicles that drive an estimated 50-billion miles each year. NAFA's members 

control assets and services well in excess of $100-billion each year. 

Although we have several reservations, the proposed Phase 2 standards are 

consistent with NAFA's support for federal policies that promote vehicle efficiency, while 

reducing emissions and fuel use. We believe the fleet industry has a unique opportunity to 

make a considerable environmental impact. NAFA's Sustainable Fleet Accreditation 

Program, developed in conjunction with CALSTART, emphasizes the economic and 

environmental benefits and overall importance of sustainability. 

As a fleet manager, I'm not opposed to increased innovation and complexity relative 

to the fleet industry as it pertains to safety, productivity and the environment. I think this 

innovation is inevitable with the rapid pace of technology. It's amazing to me with all the 

complexity that has been added to trucks in the 10 years that the industry executives are 

now beginning to understand that there is a cost to this pace of innovation and government 

regulation. 

As fleet managers, we have to consider the costs of the Phase 2, along with the 

expected costs of other current and federal requirements. The Phase 2 standards are not 

the only federal proposal that will add cost and complexities to vehicles. A case in point is 

NHTSA's proposal for rear underride crash protection of single unit trucks. NHTSA 

estimates that a requirement for rear impact guards on single unit trucks would cost 

approximately $669 million to equip approximately 342,000 vehicles. Each new federal 

regulation adds costs! 

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Today, I would like to focus on three issues - the proposed Phase 2 standards must 

be affordable, must not compromise performance, and must recognize the diverse needs of 

companies and agencies that depend on vocational vehicles and heavy duty pickups. 

Fleet managers are responsible for the entire capital budget for new and 

replacement vehicles. Multi-year capital forecasts are done annually. The capital approval 

and release for spending is an annual exercise and depends on the organization's 

resources. 

When deciding to purchase or lease vehicle, a fleet manager looks first at the cost of 

the vehicle and how that cost affects the annual vehicle replacement budget. The initial 

cost of a truck is always a concern. The projected lifecycle costs and the payback period do 

factor in to making the business case for a vehicle; and no variable cost is more important 

than fuel. The projected payback periods in the proposal are based on fuel savings, but as a 

fleet manager, after cost, my primary focus is on making sure that the vehicle and 

drivetrain features meet the specific work and duty-cycle needs, before considering fuel 

savings. 

Fleet managers appreciate the importance of continual improvement in emissions, 

but many have seen maintenance cost increases triple the rate of inflation since 2007 as a 

result of government emissions regulations. Many of us have also seen increases in engine, 

exhaust, cooling and fuel system repair costs from 2010-2014 related to engine emissions 

complexity. Complexity further compromises the industry's ability to ensure tech capability 

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is maintained, forcing fleets to maintain higher vehicle counts due to costs, complexity and 

capability. 

NAFA urges the EPA and NHTSA to undertake a more robust sensitivity analysis 

with respect to maintenance and potential scenarios. The proposal and the Regulatory 

Impact Analysis do not go far enough in looking at potential maintenance costs. 

Fleet needs are diverse. Payback periods and fuels savings vary by use. A case in 

point- the duty cycle requirements for a trim trimming company may differ from the 

requirements of an electric utility, although both may use similar vehicles. Some 

technologies will not fit in some uses. With respect to vocational vehicles, the proposal 

attempts to create silos. The agencies propose that a vocational chassis would be 

presumed to certify using the Multi-Purpose duty cycle unless some criteria is met the 

indicated that another duty cycle would be more appropriate. The agencies acknowledge 

the even within certain vocational vehicle types, vehicle use vary significantly. 

We are concerned with the statement in the proposal- "while intended service class 

may help a manufacturer decide how to classify some vehicles, we do not believe that 

intended service class would be a sufficient indicator by itself." We are not sure what this 

means! NAFA will submit additional comments on the method for assigning vocational 

chassis to duty cycles. 

In conclusion, NAFA and its members are not opposed to the proposed rule, but 

have reservations. We would like to see revisions to the proposed standards that ensure 

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that the fleet operator is able to works towards the solution that works best for the vehicles 

needed for mission of the company, agency, or institution. 

Thank you again for providing this opportunity. 

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