Powering Business Worldwide 

Testimony of Chris Hess 

Director of Public Affairs, Eaton 

Eaton Corporauon 

VelliCie Group 

13100 E MICI11Q3ll 

Avenue 

Galesburg. Ml 49053 

U.S. EPA and NHTSA Public Hearing for the Proposed Greenhouse Gas 

Emissions Standards & Fuel Efficiency Standards for Medium- & Heavy-Duty 

Engines and Vehicles 

August 6, 2015 

Chicago, IL 

Director Grundler and Director Trowbridge, 

I am Chris Hess, Director of Public Affairs for Eaton representing our Vehicle 

Group. I want to thank the Agencies for the opportunity to give testimony regarding 

the proposed rule today. 

Eaton is a power management company with 2014 sales of $22.6 billion. Eaton 

provides energy-efficient solutions that help our customers effectively manage 

electrical, hydraulic and mechanical power more efficiently, safely and sustainably. 

Eaton has approximately 102,000 employees and sells products to customers in 

more than 175 countries. 

Eaton delivers the power inside thousands of products and systems that are 

answering the demands of today's fast-changing world. 

Eaton's Vehicle Group is a leader in the design, manufacture, and supply of 

drivetrain and powertrain systems and critical components that reduce emissions 

and improve fuel economy, stability, performance, and safety of cars, light trucks 

and commercial vehicles. Products include transmissions, clutches, hybrid power 

systems, superchargers, engine valves and valve actuation systems, and engine 

controls for the global vehicle industry. 

The principal markets for the Vehicle Group are original equipment manufacturers 

and aftermarket customers of heavy-, medium-, and light-duty trucks, SUVs, 

passenger cars and agricultural equipment. 

First and foremost, Eaton appreciates the approach taken by both the U.S. EPA 

and NHTSA to reach out to stakeholders in industry for in-depth technology 

discussions early on in the development process for Phase II. It cannot be said that 

the agencies did not listen to the thoughts and concerns of the commercial vehicle 

industry and other stakeholders who are a part of the commercial vehicle value 

chain in the United States. 
As we did in Phase I, Eaton supports the push for a new generation of clean, fuelefficient commercial vehicles that will reduce greenhouse gas emissions and 

strengthen the U.S. economy. 

Phase I has been successful in that it put together a sound regulatory framework 

that is aligned with market forces to drive adoption of the most efficient 

commercially available technologies. 

We believe that the framework outlined in the NPRM for Phase 2 is a good step 

toward a final regulation that will drive innovation and, foster both technology and 

competition, while maintaining fleet diversity and incentivizing over-achievement of 

emissions and fuel economy targets. By following the structure created in Phase I, 

the agencies are relying on a proven concept that will build upon established 

regulatory structure, testing and processes that are efficient and fair. 

We are encouraged to see that the rule implements performance-based standards 

that ensure that the fuel savings certified by the test procedures end up as benefits 

to truckers and fleets on the road 

Eaton believes that the separate engine and vehicle standards found in Phase I 

should be maintained in Phase II. The separate standards reflect the reality of the 

commercial vehicle, drive adoption of efficient technologies and provide a structure 

that is proven and accepted in the U.S. truck market. 

Eaton is encouraged that the proposed calls for a long-term regulation. This will 

provide regulatory certainty that will help companies like Eaton focus R&D efforts 

on investments on advanced technologies aimed at significant fuel savings. 

This regulatory clarity in the market is critical as it allows Eaton time to work with 

our customers in the near, mid and long-term to develop technology solutions to 

meet the prescribed standards with the reliability, safety and performance 

demanded by our customers and trucking fleets. 

Furthermore, we are pleased that the EPA is expanding utilization of the powertrain 

test option introduced in Phase 1 for hybrid certification. The powertrain test 

accurately measures the fuel benefits of advanced technologies in realistic driving 

conditions. We believe the powertrain test option is a critical complement to modelbased certification. The fact that the benefits of advanced transmissions and 

controls can be visible in the vehicle assessment, through the powertrain test 

option, enables OEMs to achieve compliance though these technologies in a costeffective fashion. 

Eaton believes that deep engine-transmission integration, dual clutch technologies, 

and ultra-efficient transmissions are cost-effective way to save fuel and achieve 

compliance, without adding the weight, cost and complexity of some of the new and 

un-tested technologies. We believe that the powertrain test option ensures the 

promise of these technologies will be realized in the commercial vehicle market. 
The proposed rule is a good foundation for what the new regulations can be, giving 

clear, achievable objectives that spur innovation and deployment, while avoiding 

negative impact on the economy and promoting leadership in commercial vehicle 

fuel efficiency. 

Eaton believes that many of the technologies needed to achieve the proposed 

standards are available. Some are in low volume production, and others need a 

path into the market that recognizes and values contributions to emissions 

reduction and fuel efficiency. 

Phase II will provide clear and realistic targets for industry and will accelerate 

adoption. Eaton is looking forward to supporting the rule-making process with 

comments to EPA and NHTSA on the proposed rule in the near future. 

Thank you for your attention.