Oral Statement: EPA and NHTSA Greenhouse Gas Phase 2 Regulation Hearing 

Long Beach, CA. August 18, 2015 

Good morning. My name is Dan Kieffer, Director of Emissions Compliance for PACCAR. I'm speaking today on 

behalf of the major heavy-duty truck manufacturers in North America: Daimler, Navistar, PACCAR, and the 

Volvo Group. Together, we manufacture the vast majority of U.S. medium and heavy-duty vehicles in size 

classes 4 through 8. We appreciate the opportunity to address this hearing. 

This Phase 2 greenhouse gas and efficiency rule is historic in its scope and complexity. The proposed rule will 

regulate a wide array of customized vehicles including a broad range of tractor applications, utility trucks, 

street sweepers, concrete mixers, local delivery trucks, dump trucks, buses, motor coaches, and more. As 

OEMs, we serve the needs of the many thousands of American companies that rely on trucks to conduct their 

daily business. We must design each vehicle to meet the specifications of its intended application while 

optimizing fuel consumption and providing our customers with a reasonable return on investment. 

Today's scientific research on climate change and related environmental concerns has made our mission more 

critical, and more complex. We recognize the problem, and just as we worked closely with EPA, NHTSA and 

the other agencies to successfully implement Phase 1 reductions, so shall we also strive to address the urgent 

need for sustainable solutions in Phase 2. 

The four truck manufacturers I'm representing today are all members of the Truck and Engine Manufacturers 

Association. We fully support the testimony provided by EMA. There's a long list of technical and protocol 

issues we will work closely with the agencies to resolve. EPA and NHTSA have set very ambitious goals for this 

industry, and we will do everything we can to ensure that this regulation will translate into significant real 

world efficiency gains for our customers, as well as major benefits for society. Our goal is a classic "win-win" 

scenario, and we are hopeful we can achieve it. 

We would like to emphasize that we fully support the complete vehicle approach proposed by the agencies. 

Measurement and modeling of the full vehicle, including the engine and all other components, is the best way 

to assess the real-world performance of these vehicles. As stated by EMA, it's important to perform 

measurements and modeling using sound engineering methods, and we must get this right. We will work with 

the agencies to resolve the various certification procedures and compliance margin issues we've identified in 

the proposed rule. 

There are four points we'd like to make today in regard to engine testing and evaluation. 

First, Engines are best evaluated based on how they operate in the vehicle, considering the engine size and 

power output, the vehicle power demand, and the driveline characteristics- that is, by the full vehicle 

approach. 

Second, we must also consider the installation impact of engine-related systems, including space requirements, 

weight, and cooling demand, all of which can significantly impact the aerodynamic design of the tractor-trailer 

combination and reduce efficiency. 
The third point is that it's important to respect the simple fact that NOx emissions are proportional to engine 

work. Technology that reduces the engine work required to complete a mission, such as improved 

aerodynamics or reduced rolling resistance, inherently results in a proportionate reduction in total NOx 

output. However, this is not the case with engine efficiency improvement, where there is a well-documented 

trade-off between NOx reduction and engine efficiency. Excessive demands for stand-alone engine efficiency 

would limit the potential for NOx reduction, especially in urban duty cycles where NOx emissions are most 

critical. 

And finally, the many American businesses that rely on our vehicles are concerned about the incremental 

investment and operating costs of complex new engine technology. Putting excessive emphasis on the engine 

as a stand-alone component can result in costly engine technology that would bring little or no benefit in 

many real world applications. American businesses have already seen significant increases in vehicle costs and 

more expensive maintenance associated with increasingly complex engine and aftertreatment systems. 

Unnecessarily stringent engine standards will only exacerbate today's trend of delaying new truck purchases, 

prolonging the use of higher emitting vehicles. 

Summing up our points concerning engine regulation, the fact is that vehicle manufacturers must have the 

flexibility to optimize the complete vehicle design for maximum efficiency at the lowest cost and complexity. 

Minimizing total cost of vehicle ownership is a top priority for our customers. 

Concerning aerodynamics, measurement and analysis of tractor-trailer aerodynamics is extremely complex. 

We recently provided detailed feedback to the agencies on improvements to these procedures and would 

appreciate careful consideration of these recommendations. For now, we would like to emphasize that 

significant aerodynamic improvements can only be achieved by treating the tractor and trailer as a system. 

Even our SuperTruck designs could not achieve the tractor aerodynamic performance targets if tested 

according to the proposal. These details must be addressed. 

In response to those arguing for an even more aggressive and stringent overall efficiency target, we caution 

that the most experienced technical experts at some of the world's largest commercial vehicle manufacturers 

are still working through the implications of this proposal's requirements. As proposed, the regulation will 

limit or eliminate our ability to meet the basic customer requirements for many of the thousands of widely 

varying applications we support today. Based on our current analysis, it is not clear that the proposed 

Alternative 3 targets- which include a number of unrealistic technology penetration rates- can be achieved. 

One thing we are certain of is that we could not achieve, and therefore cannot support, the pull-ahead of 

these standards according to the plan identified as "Alternative 4" in the proposed rule. We look forward to 

further discussions with the agencies and their technical experts on these important matters. 

I appreciate the opportunity to speak on behalf of Daimler, Navistar, PACCAR and the Volvo Group, and will 

close by reaffirming our industry's commitment to working with the agencies to resolve the rule's outstanding 

issues, and to deliver major reductions in our vehicles' fuel consumption and greenhouse gas emissions. 

Thank you.