### Oral Statem ent: EPA and NHTSA Greenhou se G as Phase 2 R egul a tion Hea ring 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 ofAme rican compa n ies t hat rely on trucks to conduct their da i ly business. We must design each veh icle 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 successfu ll y imp lement 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 wi ll 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 trans late 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 wou ld like to emphasize that we fully support the com pl ete vehicle approach proposed by the agencies. Measurement and modeling of the fu ll vehicle, including the eng i ne 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 eva l uation. 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 driveli ne characteristics- that is, by the full vehicle app roach. Second, we must also consider the installation impact ofengine-relatedsystems, including space requirements, weight, and cool ing demand , all of which can significantly impact the aerodynamic design of the tractor-trailer combination and reduce efficiency.The thirdpoint is that it's important to respect the simple fact that NOx emissions are proportional to engine work. Techn ology that reduces the engine work required to complete a m ission, such as imp roved aerodynamics or re d uced roll i ng res istance, 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 engi ne efficiency. Excess ive demands for stand
-alone engine efficiency would limit the potential for NOx reduction, especiall y in urban duty cycles where NOx emissions are most critical. Andfinally, the many American businesses that rely on our vehicles are concerned about the incremental investment and operating costs ofcomplex new engine technology

. Putting excess ive emphas is on the engine as a stan d-alone component can result in costly eng i ne technology that would bring l ittle or no benefit in many real world ap pl ications

. American businesses have al ready seen significa nt increases in vehicle costs and more expensive maintenance assoc iated w ith i ncreasingly complex engine and aftertreatment systems. Unnecessarily st ri ngent eng i ne standards w ill only exacerbate today's trend of delaying new truck purchases, pro longing t he use of h igher em itting vehicles. Summ i ng up our po i nts concerning engine regulation, the fact is that vehicle manufacturers must have the flexi bility to optimize the comp lete vehicle design fo r maximum efficiency at the lowest cost and complexity. M i nim izing tota l cost of vehicle owne rsh i p is a top priority for our customers. Concerning aerodynamics, measurement and ana lysis of tractor-trailer aerodynam ics is extremely complex. We recently p rovided deta il ed feedback to the agencies on improvements to these procedures and would appreciate ca ref ul consideration of these recommendations. Fo r now, we wou ld l i ke to emphasize that significant aerodynamic improvements can on ly be achieved by t reating the tractor and trailer as a system. Even our SuperTruck des igns could not ach ieve the tractor aerodynamic performance targets if tested according to the proposal. These detai ls must be addressed. In response to those arg u ing fo r an even more aggressive and stringent overa ll efficiency target, we caution that the most experienced technica l experts at some of the world's largest commercia l vehicle manufacturers are still working through the imp l ications of this proposal's requirements. As proposed, the reg ul ation will limit o r eliminate ou r abi li ty to meet the basic customer requi rements for many of the thousands of widely varying applications we support today

. Based on our current analys is, it is not clear that the proposed Alternative 3 targets- wh ich include a number of unreal istic techno logy penet ration rates- can be achieved. One thing we are ce rtain of is that we cou ld not ach ieve, and therefore cannot support, the pull-ahead of these standards according to the plan ident ified as "Alternative 4" in the proposed rule

. We look forward to fu rther discussions with the agencies and thei r technical experts on these important matters

. I appreciate the opportun ity to speak on behalf of Da i mle r, Navistar, PACCAR and the Volvo Group, and will close by reaffi rming our industry's commitment to working with the agencies to reso lve the rule's outstanding issues, and to deliver major reductions in our vehicles' fuel consumption and greenhouse gas emissions

. Thank you .