# NAFA FleetManagementAssodation



### STATEMENT OF CHRIS WILLIAMS NAFA FLEET MANAGEMENT ASSOCIATION BEFORE THE NATIONAL HIGHWAY TRAFFIC SAFETY ADMINIS T RATION AND THE U.S. ENVIRONMENTAL PROTECTION AGENCY LONG BEACH, CALIFORNIA AUGUST 18, 2015

Thank yo u ve ry much for provid ing this opportunity to speak today on the Phase 2 Greenhouse Gas Emiss io ns Standards and Fu e l Efficiency Standards for Medium- and Heavy-Duty Engin es and Veh icles. I am C h ris Williams a nd here today day on behalf of professio n a l fleet managers and NAFA Fleet Man ageme n t Associatio n . I am a NAFA member and the Fleet Manager for Gothi c L andscape, where I am responsible for ve hicl es in California, Arizona and Nevada. Previously, for 30 years I was the Fleet Manager for Verizon with responsibi li ty for vehicles in the Cali fornia, Texas and Florida. NAFA's members are responsib le for th e majority of class 3 to 7 trucks in fleets in the United States and Canada. NAFA is the associatio n for professionals who manage fleets of sedans, public safety ve hicles, truc ks, and buses of all types and sizes, a nd a wide range of military a n d 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 . orgacquisition, 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 contro l assets and services well in excess of $100-billion each year. Altho ugh we have several reservations, the proposed Phase 2 standards are consistent with NAFA's support for federa l policies that promote ve hicl e efficiency, while reducing emissio ns and fuel use. We believe the fleet industry has a unique opportunity to make a considerable env ironmenta l impact. NAFA's Sustainable Fleet Accreditation Program, developed in conjunction with CALSTART, emphasizes the economic and environmental benefits a nd overall importance of sustainabi li ty. As a fleet manager, I'm not opposed to increased innovation and comp lexity re lative to the fleet industry as it pertains to safety, productivity and the environment. I think this innovation is inevitab le with the rapid pace of techno logy. It's amazing to me with all the comp lexity that has been added to trucks in the 10 years that the indu stry exec utives are now beginning to understand that there is a cost to this pace of in n ovation and government regulation. As fleet managers, we have to consider the costs of the Phase 2, a long with the expected costs of other current and federal requirements . The Phase 2 standards are not the only federal proposal that will add cost a nd comp lexities 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 wou ld cost approximately $669 million to equip approximate l y 342,000 vehicles. Each new federal regulation adds costs! 2Today, 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 vocationa l vehicles and heavy duty pickups. Fleet managers are responsib le for the entire capital budget for new and replacement vehicles. Multi-year capital forecasts are done annually . The capital approval and re lease 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 rep lacement budget. The initial cost of a truck is a lways a concern. The projected lifecycle costs and the payback period do factor in to maki ng the business case for a vehicle; and no variab le cost is more important than fuel. The projected payback periods in the proposal are based on fue l 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 f u el savings. Fleet managers appreciate the importance of contin ua l improvement in emissions, but many have seen maintenance cost increases trip le the rate of inflation since 2007 as a resu lt of government emissions regulations. Many of us have a lso seen increases in engine, exhaust, coo ling and f u el system repair costs from 2010-2014 related to engine emissions complexity. Complexity fu rther compromises the industry's ab il ity to ensure tech capability

3is maintained, forcing fleets to mai ntain higher ve hicle counts due to costs, complexity and capability. NAFA urges the EPA and NH TSA to undertake a more robust sensitivity analysis with respect to main tenance and potential scenarios. The proposal and the Regulatory I mpact Analysis do not go far enough in looking at potential maintenance costs. Fleet needs are diverse. Payback periods and fue ls 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 simi lar vehicles. Some techno logies will not fit in some uses . With respect to vocational vehicles, the proposal attempts to create silos. The agencies propose that a vocationa l chassis wou ld be presumed to certify using the Multi-Purpose duty cycle unless some criteria is met the indicated that another duty cycle wo u ld be more appropriate. The agencies acknow ledge the even within certain vocational vehicle types, vehicle use vary significantl y. We are concerned with the statement in the proposal- "while intended service class may he lp 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 wi ll submit additional comments on the method for assigning vocational chassis to duty cycles. I n conclusion, NAFA and its members are not opposed to the p roposed rule, but have reservations . We would li ke to see revisions to the proposed standards that ensure

4that the fleet operator is able to works towards the so luti on that works best for the vehicles needed for mission of the company, agency, or institution . Thank you agai n for providing this opportunity.

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